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EVANS v. COMMISSIONER

Docket No. 9072-86.

62 T.C.M. 614 (1991)

T.C. Memo. 1991-421

John S. Evans and Sue A. Evans v. Commissioner.

United States Tax Court.

Filed August 27, 1991.

Attorney(s) appearing for the Case

Walter J. Rockler and Richard L. Hubbard, for the petitioner.

Elizabeth P. Flores, for the respondent.

Supplemental Memorandum Opinion

TANNENWALD, Judge:

This case is again before us on petitioners' motion for reconsideration of that portion of our opinion on remand (T.C. Memo. 1991-272) which denies them the investment credit to the extent of their share of the cash and recourse note investment of the partnership in respect of "Heartbeat." Petitioners assert that they are entitled to such credit because they were lenders...

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