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GIANARIS v. COMMISSIONER

Docket Nos. 8234-87, 21142-89.

64 T.C.M. 1229 (1992)

T.C. Memo. 1992-642

George J. Gianaris and Camille Gianaris v. Commissioner. Harmonic Associates, Limited Partnership, Winston Frost, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 3, 1992.

Attorney(s) appearing for the Case

Richard P. Swanson and Edward Scarvalone (specially recognized), 520 Madison Ave., New York, N.Y., for the petitioners. Jane B. Wilson, Peter J. Graziano, and Maria Stabile, for the respondent.

Memorandum Findings of Fact and Opinion

HALPERN, Judge:

By notice of deficiency dated January 15, 1987, respondent determined deficiencies in petitioners George and Camille Gianaris' Federal income taxes for 1980 and 1981, along with an addition to tax for 1981, and increased interest for both years. By notice of final partnership administrative adjustment (FPAA) dated July 17, 1989, respondent made certain adjustments to the partnership return of Harmonic...

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