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RYAN v. COMMISSIONER

Docket No. 28614-86.

61 T.C.M. 1801 (1991)

T.C. Memo. 1991-49

Robert N. Ryan v. Commissioner.

United States Tax Court.

Filed February 7, 1991.

Attorney(s) appearing for the Case

John L. Burghardt, 3120 Cohasset Rd., Chico, Calif., for the petitioner.

Thomas M. Rohall, for the respondent.

Memorandum Opinion

SHIELDS, Judge.

Respondent determined a deficiency of $17,550 in petitioner's Federal income tax for 1981. In his answer respondent asserted an undetermined amount of additional interest pursuant to section 6621(c) (formerly section 6621(d)).1 The matter is before us at this time on petitioner's motion to dismiss for lack of jurisdiction, which the parties have agreed is to be treated as a motion for partial...

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