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MILLSTEIN v. COMMISSIONER

Docket No. 25950-87.

67 T.C.M. 1956 (1994)

T.C. Memo. 1994-14

Irving Millstein and Phyllis Millstein v. Commissioner.

United States Tax Court.

Filed January 11, 1994.

Attorney(s) appearing for the Case

Martin Berlin, 29 Broadway, New York, N.Y., for the petitioners. George Soba, for the respondent.

Memorandum Findings of Fact and Opinion

LARO, Judge:

Irving Millstein and Phyllis Millstein (petitioners) petitioned the Court for redetermination of respondent's determinations reflected in her notice of deficiency. Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $48,041 and an addition to tax of: (1) $4,500 under section 6659,1 or (2) in the alternative, $3,750 under section 6661...

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