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CASA DE LA JOLLA PARK, INC. v. COMMISSIONER

Docket No. 28972-87.

94 T.C. 384 (1990)

CASA DE LA JOLLA PARK, INC., A CALIFORNIA CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 13, 1990.

Attorney(s) appearing for the Case

Chris John Wenthur, for the petitioner.

Sylvia L. Shaughnessy, for the respondent.

WRIGHT, Judge:

By notice of deficiency dated June 1, 1987, respondent determined deficiencies in petitioner's withholding of Federal income tax at source for taxable years ending December 31, 1982, and December 31, 1983, of $48,981 and $79,236, respectively.

The issues for decision are: (1) Whether petitioner was responsible under section 1441(a)1 for withholding tax on interest...

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