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HOLLEN v. COMMISSIONER

Docket No. 5586-97.

79 T.C.M. 1719 (2000)

T.C. Memo. 2000-99

Michael C. Hollen and Joan L. Hollen v. Commissioner.

United States Tax Court.

Filed March 24, 2000.

Attorney(s) appearing for the Case

Paul F. Christoffers, for the petitioners. Lisa K. Hartnett, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1988 of $79,308 and additions to tax under sections 6653 and 6661(a) of $3,965 and $19,827, respectively.1 After concessions,2 the issues for decision are: (1) Whether petitioners were required to report and pay income tax on a one-third distributive share...

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