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LINCIR v. COMMISSIONER

Docket No. 22934-89.

115 T.C. 293 (2000)

TOM I. LINCIR AND DIANE C. LINCIR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 27, 2000.

Attorney(s) appearing for the Case

Michael D. Savage, for petitioners.

Gary D. Kallevang, for respondent.

SUPPLEMENTAL OPINION

DAWSON, Judge:

This matter is before the Court for resolution of the parties' dispute over the terms of the decision to be entered in this case pursuant to Rule 155.1 Although the parties generally agree as to the decision to be entered in this case, petitioners contend that it should include the following statement:

The penalties due under section 6621(c) and section 6653(a)(2) are to be determined...

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