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GERINGER v. COMMISSIONER

Docket No. 4935-90.

61 T.C.M. 1738 (1991)

T.C. Memo. 1991-32

Harold I. Geringer and Eleanore N. Geringer v. Commissioner.

United States Tax Court.

Filed January 28, 1991.

Attorney(s) appearing for the Case

Harold I. Geringer, pro se. Victoria Wilson Fernandez, for the respondent.

Memorandum Opinion

PANUTHOS, Special Trial Judge:

This case is before the Court on the parties' cross-motions for summary judgment pursuant to Rule 121.1 The sole issue for decision is whether a closing agreement executed by the parties precludes respondent from determining an addition to tax against petitioners pursuant to section 6661 for taxable year 1982.

Respondent examined the 1981 tax return of Huron Electronics...

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