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HAHN v. COMMISSIONER

Docket No. 29461-85.

58 T.C.M. 1294 (1990)

T.C. Memo. 1990-43

William C. Hahn and Ella J. Hahn v. Commissioner.

United States Tax Court.

Filed January 23, 1990.

Attorney(s) appearing for the Case

Peter R. Stromer, 15951 Los Gatos Blvd., Los Gatos, Calif., for the petitioners. David H. Peck, Steven B. Jacobs, Jeffrey N. Kelm and Albert Balboni, for the respondent.

Memorandum Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1979 and 1980 in the respective amounts of $4,587 and $18,814, plus additions to tax under section 6653(a)1 in the respective amounts of $229 and $941. By amended answer, respondent determined that the entire deficiency was attributable to tax motivated transactions and thus seeks increased interest pursuant to section...

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