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QUITA v. COMMISSIONER

Docket No. 16512-86.

55 T.C.M. 1289 (1988)

T.C. Memo. 1988-309

Jaime E. and Helene M. Quita v. Commissioner.

United States Tax Court.

Filed July 25, 1988.

Attorney(s) appearing for the Case

John W. Knapp, 126 Second Ave., San Mateo, Calif., for the petitioners. William Reese, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income tax for the 1982 taxable year. The parties have settled all issues raised in the statutory notice1 but petitioners have raised the issue of whether they were nominees as to a portion of the interest income reported on their 1982 Federal income tax returns now claimed to have been reported in error...

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