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COLLINS v. COMMISSIONER

Docket No. 12480-88.

60 T.C.M. 542 (1990)

T.C. Memo. 1990-441

Andrew L. and Helen W. Collins, Petitioners v. Commissioner.

United States Tax Court.

Filed August 15, 1990.

Attorney(s) appearing for the Case

Murray H. Falk, for the petitioners.

Margaret R. Reichenberg and Marlene A. Kristovich, for the respondent.

Memorandum Findings of Fact and Opinion

NAMEROFF, Special Trial Judge.

This case was heard pursuant to the provisions of section 7443A(b) of the Code1 and Rule 180 et seq. Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1986 in the amount of $5,185, plus additions to tax under sections 6653(a)(1)(A) and 6653(a)(1)(B) in the amounts of $259.25 and 50 percent of the interest due on the...

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