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ROMAN SYSTEMS, LTD. v. COMMISSIONER

Docket No. 13936-78.

42 T.C.M. 7 (1981)

T.C. Memo. 1981-273

Roman Systems, Ltd. v. Commissioner.

United States Tax Court.

Filed June 1, 1981.

Attorney(s) appearing for the Case

John A. Mraz and Anthony L. Giordano, 623 East Trade St., Charlotte, N.C., for the petitioner. Frank D. Armstrong, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioner's Federal income taxes as follows:

  Taxable Year Ended            Deficiency

    Sept. 30, 1975 ...........  $13,637.00
    Sept. 30, 1976 ...........   11,255.36

After the settlement of some of the issues, the sole issue for decision is whether rental payments made by the petitioner to a partnership established...

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