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MAX v. COMMISSIONER

Docket No. 6843-94.

71 T.C.M. 3191 (1996)

T.C. Memo. 1996-281

Max M. and Joan E. Greenberg v. Commissioner.

United States Tax Court.

Filed June 19, 1996.

Attorney(s) appearing for the Case

Andrew M. Glatt, for the petitioners. Christine V. Olsen, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined an $11,644 deficiency in petitioners' 1990 Federal income tax, and a $2,329 section 6662(a) accuracy-related penalty for such year.

The principal issue for decision concerns the proper characterization of payments petitioners received from or through an entity known as Pioneer Mortgage in 1990 totaling $44,396 (viz, whether...

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