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MODERNAGE DEVELOPERS, INC. v. COMMISSIONER

Docket No. 26308-91.

66 T.C.M. 1575 (1993)

T.C. Memo. 1993-591

Modernage Developers, Inc. v. Commissioner.

United States Tax Court.

Filed December 15, 1993.

Attorney(s) appearing for the Case

Howard I. Rosen, 41 Willow Rd., Wellesley, Mass., for the petitioner. Robert E. Marum, for the respondent.

Memorandum Findings of Fact and Opinion

HALPERN, Judge:

By notice of deficiency dated August 23, 1991, respondent determined deficiencies and additions to tax against Modernage as follows:

Tax Year Ending                       Addition to Tax
   June 30               Deficiency     Sec. 6651(a)

   1988 ..............    $ 32,847          --
   1989 ..............     729,892        $36,495

Unless...

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