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MALACHINSKI v. COMMISSIONER

Docket No. 13501-94.

77 T.C.M. 2092 (1999)

T.C. Memo. 1999-182

Leon S. Malachinski v. Commissioner.

United States Tax Court.

Filed June 1, 1999.

Attorney(s) appearing for the Case

Michael G. Boylan, Geneva, Ill., for the petitioner. Joseph T. Ferrick, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined a deficiency of $43,750 in petitioner's Federal income taxes for 1980 and an addition to tax of $2,188 under section 6653(a).1 Respondent also determined that, once the deficiency is determined, petitioner is liable for increased interest on an underpayment attributable to a tax-motivated transaction as defined in section 6621(c). After concessions,

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