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SULLIVAN v. COMMISSIONER

Docket No. 7933-98.

78 T.C.M. 586 (1999)

T.C. Memo. 1999-341

John L. Sullivan v. Commissioner.

United States Tax Court.

Filed October 12, 1999.

Attorney(s) appearing for the Case

Charles J. Reilly, for the petitioner. Robert E. Marum, for the respondent.

MEMORANDUM OPINION

JACOBS, Judge:

Respondent determined a $72,600.30 deficiency, a $17,565.58 addition to tax under section 6651(a)(1), and a $4,734.19 addition to tax under section 6654 with respect to petitioner's 1989 Federal income tax. Respondent now concedes that petitioner is not liable for the addition to tax under either section 6651(a) or 6654.

Following other concessions, the issues for decision are: (1) Whether interest received as part...

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