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QURESHI v. COMMISSIONER

Docket No. 18099-93.

71 T.C.M. 2702 (1996)

T.C. Memo. 1996-169

G. Dastgir and Mary A. Qureshi v. Commissioner.

United States Tax Court.

Filed April 3, 1996.

Attorney(s) appearing for the Case

Warren Neal Nemiroff, Los Angeles, Calif., for the petitioners. Stephen M. Friedberg, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

Respondent determined a $7,517 deficiency in petitioners' 1984 Federal income tax, a $2,255 addition to tax for valuation overstatement pursuant to section 6659, and additional interest pursuant to section 6621(c).1 As an alternative to the section 6659 addition to tax, respondent determined a $1,879 addition to tax for substantial understatement of tax pursuant to section...

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