T.C. Memo. 1997-49
UNITED STATES TAX COURT
RICHARD AND BRENDA NELON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1253-94. Filed January 28, 1997.
E. K. Morley, for petitioners.
Amy J. Sargent, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: In a notice of deficiency dated October 21,
1993, respondent determined the following income tax deficiencies
and additions with respect to petitioner Richard Nelon's Federal
income taxes:
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