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ROBERTSON v. COMMISSIONER

Docket No. 15586-88.

77 T.C.M. 1849 (1999)

T.C. Memo. 1999-130

Lowell L. and Marilyn A. Robertson v. Commissioner.

United States Tax Court.

Filed April 20, 1999.

Attorney(s) appearing for the Case

Albert H. Turkus and Frederick T. Goldberg, for the petitioners. Michael D. Wilder and Paulette Segal, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

WHALEN, Judge:

This case is before the Court to reconsider that part of our opinion in Robertson v. Commissioner [Dec. 50,078(M)], filed at T.C. Memo. 1994-424 (hereinafter Robertson I), holding petitioners liable for additions to tax under sections 6653(a)(1) and (2) and 6661. All section references are to the Internal Revenue Code, as amended and in effect...

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