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INI, INC. v. COMMISSIONER

Docket Nos. 3156-93, 3368-94.

69 T.C.M. 2113 (1995)

T.C. Memo. 1995-112

INI, Inc. v. Commissioner. Spalding Partners, Ltd. v. Commissioner.

United States Tax Court.

Filed March 20, 1995.

Attorney(s) appearing for the Case

William E. Frantz, John B. Grattan, and Donald B. DeLoach, 6100 Lake Forest Dr., Atlanta, Ga., for the petitioner INI, Inc. Mark S. Lange, Jennifer L. Hampton, and John L. Watkins, 303 Peachtree St., Atlanta, Ga., for the petitioner Spalding Partners, Ltd. David Delduco, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

In these consolidated cases respondent determined deficiencies in and additions to petitioners Federal income tax for the fiscal year ending September 30, 1989, as follows:

Petitioner Spalding Partners, Ltd.

                  Additions to Tax
             -------------------------
              Section
Deficiency   6653(a)(1)   Section 6661

$413,159...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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