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YAMAMOTO v. COMMISSIONER

Docket No. 13280-85.

60 T.C.M. 1050 (1990)

T.C. Memo. 1990-549

Hirotoshi Yamamoto and Shizuko Yamamoto v. Commissioner.

United States Tax Court.

Filed October 23, 1990.

Attorney(s) appearing for the Case

Hirotoshi Yamamoto, pro se. Henry E. O'Neill, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1980 and 1981 in the amounts of $103,933 and $1,153,327, respectively.

After a concession by respondent,1 the issues for decision are as follows:2

(1) Whether certain interest expenses of petitioners for 1981 are subject to the section...

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