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GRACE FOREIGN EXCHANGE CORP. v. COMMISSIONER

Docket No. 1291-92.

68 T.C.M. 1464 (1994)

T.C. Memo. 1994-621

Grace Foreign Exchange Corporation v. Commissioner.

United States Tax Court.

Filed December 19, 1994.

Attorney(s) appearing for the Case

Peter S. Buchanan, 170 Columbus Ave., San Francisco, Calif., for the petitioner. Charlotte A. Mitchell, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for fiscal year ended May 31, 1987, of $559,531, and additions to tax of $27,976 under section 6653(a)(1)(A),1 50 percent of interest due on the deficiency under section 6653(a)(1)(B), and $139,883 under section 6661.

The issues for decision are:...

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