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MAGAZINER v. COMMISSIONER

Docket No. 9368-76.

37 T.C.M. 873 (1978)

T.C. Memo. 1978-205

Martin Magaziner and Phyllis Magaziner v. Commissioner.

United States Tax Court.

Filed June 5, 1978.

Attorney(s) appearing for the Case

Norman Rabineau, 117 Eldrid Dr., Silver Spring, Md., for the petitioners. Robert E. Dallman, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1970 and 1971 in the amounts of $9,615.32 and $8,755.59, respectively. The sole issue for decision is whether, under section 704(b)(2), I.R.C. 1954,1 the principal purpose of the allocation of specific percentages of the amounts of interest...

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