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ESTATE OF SALINITRO v. COMMISSIONER

Docket No. 39325-86.

63 T.C.M. 2994 (1992)

T.C. Memo. 1992-274

Estate of Nicholas Salinitro, Deceased, Antoinette Salinitro, Executrix, and Antoinette Salinitro v. Commissioner.

United States Tax Court.

Filed May 13, 1992.

Attorney(s) appearing for the Case

Stephen Seltzer, 469 Seventh Ave., New York, N.Y., for the petitioners. Robert D. Kaiser, for the respondent.

Memorandum Opinion

SHIELDS, Judge:

This matter is before us at this time on respondent's motion for leave to file an amended answer in order to increase the deficiency and addition to interest under section 6621(c)2 previously determined by respondent. Petitioners object to the filing of respondent's amended answer on the grounds that this case was settled in December of 1987...

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