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FONTE v. COMMISSIONER

Docket No. 37305-84.

55 T.C.M. 898 (1988)

T.C. Memo. 1988-227

Robert U. Fonte v. Commissioner.

United States Tax Court.

Filed May 19, 1988.

Attorney(s) appearing for the Case

Russell B. Longaway, for the petitioner. Donna J. Rice, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By a notice of deficiency dated August 16, 1984, respondent determined a deficiency of $7,568 in petitioner's Federal income tax for taxable year 1981 and an addition to tax under section 6651(a) in the amount of $564.

After concessions,1 the issues for consideration are (1) whether petitioner was engaged in the trade or business of selling real estate and if so whether...

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