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FOLEY v. COMMISSIONER

Docket No. 16573-87.

69 T.C.M. 1661 (1995)

T.C. Memo. 1995-16

Margaret R. Foley v. Commissioner.

United States Tax Court.

Filed January 17, 1995.

Attorney(s) appearing for the Case

Ernest D. Defoy and Walter McCrary (specially recognized), for the petitioner. Donza M. Poole, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge.

Respondent determined a $29,349.17 deficiency in petitioner's 1982 Federal income tax and additions to tax for negligence under section 6653(a) and for substantial understatement of tax under section 6661; and increased interest under section 6621(c) for substantial underpayment due to tax-motivated transactions.

Petitioner concedes the adjustments in the notice of deficiency. The sole issue...

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