Manaharlal C. Parekh and Elizabeth Parekh - Page 1

                                 T.C. Memo. 1998-151                                  

                               UNITED STATES TAX COURT                                

              MANAHARLAL C. PAREKH AND ELIZABETH PAREKH, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21418-95.                   Filed April 27, 1998.           

               Michael D. Cropper, for petitioners.                                   
               Michael C. Prindible, for respondent.                                  

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               VASQUEZ, Judge:  Respondent determined deficiencies in                 
          petitioners' 1990 and 1991 Federal income taxes in the amounts of           
          $117,021.24 and $12,343.39, respectively.                                   
               All section references are to the Internal Revenue Code in             
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  

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