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BHATIA v. COMMISSIONER

Docket No. 21830-94.

72 T.C.M. 696 (1996)

T.C. Memo. 1996-429

Arun and Asmita Bhatia v. Commissioner.

United States Tax Court.

Filed September 24, 1996.

Attorney(s) appearing for the Case

Barry L. Gardiner, Fort Lee, N.J., for the petitioners.

Paul N. Schneiderman, for the respondent.

MEMORANDUM OPINION

TANNENWALD, Judge:

1 Respondent determined a deficiency in petitioners' 1987 Federal income tax in the amount of $138,290 plus an addition to tax of $34,573 under section 6661.1

The issues for decision are whether petitioners: (1) Are entitled to a passthrough loss from a wholly owned S corporation, and (2) are liable for an addition to tax pursuant to section 6661 for a substantial understatement of...

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