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SILVERMAN v. COMMISSIONER

Docket Nos. 21592-93, 21594-93.

105 T.C. 157 (1995)

DAVID R. SILVERMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT MEREDITH M. SILVERMAN MARKS AND DAVID R. SILVERMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 6, 1995.

Attorney(s) appearing for the Case

James P. Redding, for petitioners.

Robert E. Marum, for respondent.

OPINION

RAUM, Judge:

The Commissioner determined deficiencies in income taxes and an increased rate of interest on those deficiencies as follows:

                 Docket No. 21594-93

                                    Increased interest
  Year       Deficiency               sec. 6621(c)1

  1975       $31,781         120% of interest due on $20,781
  1976        51,979...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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