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COLEMAN v. COMMISSIONER

Docket No. 28983-87, 34893-87.

60 T.C.M. 889 (1990)

T.C. Memo. 1990-511

Jerome P. Coleman v. Commissioner. Edward M. and Margaret A. Maher v. Commissioner.

United States Tax Court.

Filed September 25, 1990.

Attorney(s) appearing for the Case

Richard A. Levine and Theodore D. Peyser, 30 Rockefeller Plaza, New York, N.Y., for the petitioners. Vincent J. Guiliano and Elizabeth P. Flores, for the respondent.

Supplemental Memorandum Opinion

WELLS, Judge:

The instant case1 is before us on petitioners' motion for reconsideration of our opinion in Coleman v. Commissioner [Dec. 46,720(M)], T.C. Memo. 1990-357, filed on July 16, 1990 (prior opinion).

Petitioners contend, among other things, that the addition to tax for negligence was imposed erroneously against petitioners Edward and...

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