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GARCIA v. COMMISSIONER

Docket No. 27112-92.

67 T.C.M. 1950 (1994)

T.C. Memo. 1994-12

Ruben and Maria E. Garcia v. Commissioner.

United States Tax Court.

Filed January 10, 1994.

Attorney(s) appearing for the Case

Heriberto Medrano, 1101 W. Tyler, Harlingen, Tex., for the petitioners. Derek B. Matta, for the respondent.

Memorandum Opinion

PARR, Judge:

This matter is before the Court on respondent's motion for partial summary judgment filed November 12, 1993, pursuant to Rule 121(c).1 In her notice of deficiency, respondent determined a deficiency of $23,652 in petitioners' Federal income tax for 1988. Respondent also determined that petitioner Ruben Garcia was liable for the addition to tax for fraud under section 6653(b) in the amount of $17...

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