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JACKSON v. COMMISSIONER

Docket No. 45345-85.

61 T.C.M. 2806 (1991)

T.C. Memo. 1991-250

John F. Jackson, Jr., and Shirley Jackson v. Commissioner.

United States Tax Court.

Filed June 5, 1991.

Attorney(s) appearing for the Case

Richard R. Helmick, 1350 17th St., Denver, Colo., for the petitioners. Carol C. Mason, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in individual income tax against petitioners for 1982 in the amount of $6,349, and determined that petitioners are liable for an increased rate of interest on the entire deficiency under section 6621.1 The issues for decision are as follows:

(1) Whether petitioners are entitled to deduct...

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