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FLEISCHAKER v. COMMISSIONER

Docket No. 6668-97.

78 T.C.M. 1257 (1999)

T.C. Memo. 1999-427

William J. Fleischaker and Donni L. Fleischaker v. Commissioner.

United States Tax Court.

Filed December 30, 1999.

Attorney(s) appearing for the Case

Joseph W. Martin and Frank H. McGregor III, for the petitioners. C. Glenn McLoughlin, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined deficiencies in petitioners' Federal income tax of $101,342 for 1991 and $22,513 for 1992 and accuracy-related penalties under section 6662(a)1 of $20,268 for 1991 and $4,503 for 1992.

After concessions by the parties,2 the issues for decision are:

1. Whether petitioners may deduct: (a) Loan guaranty payments...

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