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ESTATE OF HAMMER v. COMMISSIONER

Docket No. 32436-87.

59 T.C.M. 158 (1990)

T.C. Memo. 1990-145

Estate of Leland C. Hammer, Deceased, Douglas R. Hammer, Executor, and Douglas R. and Joann L. Hammer v. Commissioner.

United States Tax Court.

Filed March 20, 1990.

Attorney(s) appearing for the Case

Timothy Horne, 2251 Middlesex Dr., Toledo, Ohio, and David W. Zoll, 6605 W. Central Ave., Toledo, Ohio, for the petitioners. Karen J. Goheen, for the respondent.

Memorandum Opinion

SHIELDS, Judge:

This matter is before us at this time on petitioners' motion for litigation costs pursuant to section 74301 and Rule 231. Respondent determined deficiencies in and additions to petitioners' income taxes as follows:

                                                      Additions to Tax, Sections
  Year                                  Tax     6653(a) or (a...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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