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HATTIER v. COMMISSIONER

Docket No. 3724-86.

58 T.C.M. 1109 (1990)

T.C. Memo. 1990-2

Craig J. Hattier and Charlotte Wood Hattier v. Commissioner.

United States Tax Court.

Filed January 2, 1990.

Attorney(s) appearing for the Case

Gary James Joslin, for the petitioners. Linda West, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $55,179, together with additions to tax pursuant to sections 6653(a)(1)1 6653(a)(2) and 6661(a) in the respective amounts of $2,759, 50 percent of the interest due on $55,179, and $5,518. Respondent also determined that the entire deficiency was attributable to a tax motivated transaction...

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