HAGESTAD v. COMMISSIONER

Docket No. 14920-95.

73 T.C.M. 3047 (1997)

T.C. Memo. 1997-273

Grant K. Hagestad v. Commissioner.

United States Tax Court.

Filed June 17, 1997.


Attorney(s) appearing for the Case

Jon T. Flask, Vienna, Va., for the petitioner. Warren P. Simonsen, for the respondent.


MEMORANDUM OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $123,586.00 in petitioner's Federal income tax for the 1987 taxable year, and increased interest under section 6621(c)1 of $31,027. After concessions by the parties, the issue for decision is whether respondent may adjust petitioner's 1987 income under the mitigation provisions found in sections 1311 to 1315.

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