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CICHY v. COMMISSIONER

Docket No. 9176-89.

61 T.C.M. 2913 (1991)

T.C. Memo. 1991-270

Theodore D. Cichy, Deceased, and Gloria A. Cichy v. Commissioner.

United States Tax Court.

Filed June 12, 1991.

Attorney(s) appearing for the Case

Karen Kobialka, 77 West Washington St., Chicago, Ill., for the petitioners. Jonathan P. Decator, for the respondent.

Memorandum Opinion

HALPERN, Judge:*

Respondent determined deficiencies in petitioners' income taxes for calendar years 1980, 1981, and 1983. The deficiencies were limited to additions to tax. Respondent also determined that the rate of interest prescribed by section 6621(c)(1)1 (formerly section 6621(d)(1)) would apply for 1981 and 1983. The parties have agreed that the only issue to be decided by...

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