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HARNESS v. COMMISSIONER

Docket No. 33005-88.

62 T.C.M. 128 (1991)

T.C. Memo. 1991-321

Donald K. and Joyce I. Harness v. Commissioner.

United States Tax Court.

Filed July 11, 1991.

Attorney(s) appearing for the Case

Richard G. Smith, P.O. Box 1617, Boise, Ida., for the petitioners. James D. Hill, for the respondent.

Memorandum Opinion

PETERSON, Chief Special Trial Judge:

This case is before the Court on petitioners' Motion for Partial Summary Judgment. The facts are undisputed. The legal issue for us to decide is whether petitioners are liable for the addition to tax for valuation overstatements pursuant to section 6659.

Petitioners were legal residents of Boise, Idaho, at the time the petition was filed.

Petitioners were looking for a long-term investment...

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