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NEGRI v. COMMISSIONER

Docket No. 26374-90.

65 T.C.M. 2953 (1993)

T.C. Memo. 1993-261

Peter F. Negri and Elizabeth Negri v. Commissioner.

United States Tax Court.

Filed June 14, 1993.

Attorney(s) appearing for the Case

Cindy V. Schlaefer, 53 Wall St., New York, N.Y., for the petitioner. Halvor Adams, for the respondent.

Memorandum Opinion

WOLFE, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 By notice of deficiency dated August 24, 1990, respondent determined a deficiency of $7,790 in petitioners' 1985 Federal income tax.

After concessions by petitioners, the issues for our decision are: (1) Whether respondent correctly determined that interest in the amount of...

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