T.C. Memo. 2005-121
UNITED STATES TAX COURT
EUGENE MCCLELLAND AND IONE MCCLELLAND, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1327-02, 1129-03. Filed May 24, 2005.
Paul V. Sween, for petitioner Eugene McClelland.
William A. Vincent, for petitioner Ione McClelland.
Blaine Holiday, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: By separate notices of deficiency, respondent
determined deficiencies in petitioners’ Federal income tax of
$345,037 for the tax year 1997 and $97,037 for the tax year 1998.
Petitioners timely petitioned the Court for redetermination of
respondent’s determinations in both notices, and the cases were
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