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HEASLEY v. COMMISSIONER

Docket No. 46147-86.

61 T.C.M. 2503 (1991)

T.C. Memo. 1991-189

David E. Heasley and Kathleen Heasley v. Commissioner.

United States Tax Court.

Filed April 29, 1991.

Attorney(s) appearing for the Case

John D. Copeland, 8222 Douglas Ave., Dallas, Tex., for the petitioners. David L. Click, for the respondent.

Supplemental Memorandum Opinion

GERBER, Judge:

Petitioners seek the award of attorney's fees and litigation costs in this case. Petitioners had conceded the income tax deficiencies for three years involving a "tax shelter" and litigated the question of the additions to tax under sections1 6653(a), 6659, and 6661. Petitioners also contested the determination of the increased rate of interest under section 6621(c). We held that...

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