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BRNILOVICH v. COMMISSIONER

Docket No. 11173-88.

58 T.C.M. 538 (1989)

T.C. Memo. 1989-583

David and Diane A. Brnilovich v. Commissioner.

United States Tax Court.

Filed October 30, 1989.

Attorney(s) appearing for the Case

James J. Everett, 3030 W. Deer Vally Rd., Phoenix, Ariz., for the petitioners. Mark S. Pendery, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency in petitioners' 1985 Federal income tax of $12,695. Following concessions, the remaining issues are (1) whether petitioners misreported a $62,771 item of ordinary income as long-term capital gain, and, if so, (2) whether petitioners are liable for additions to tax under section 6653(a)(1) and 6653(a)(2).1

Findings of Fact<...

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