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GANZ v. COMMISSIONER

Docket No. 43167-85.

59 T.C.M. 604 (1990)

T.C. Memo. 1990-243

Burt Ganz and Rochelle Ganz v. Commissioner.

United States Tax Court.

Filed May 21, 1990.

Attorney(s) appearing for the Case

Bernard Kobroff, 36 W. 44th St., New York, N.Y., for the petitioners. Michael D. Wilder, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable years 1973 and 1974 in the amounts of $5,026 and $3,424, respectively, and, pursuant to section 6621(c),1 formerly section 6621(d), an increased interest rate for the underlying deficiencies. The issues for decision are whether certain "cash and carry" silver transactions were bona fide...

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