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GARFIELD v. COMMISSIONER

Docket No. 4017-05.

92 T.C.M. 496 (2006)

T.C. Memo. 2006-267

Nathaniel H. and Carol A. Garfield v. Commissioner.

United States Tax Court.

December 18, 2006.

Attorney(s) appearing for the Case

Ronald J. Cohen and David S. Schwan, for petitioners.

Frank J. Jackson and Karen A. Rennie, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

The issues for decision are whether income received by petitioners should be treated as ordinary income or long-term capital gain and whether petitioners are liable for the section 66621 accuracy-related penalty.

FINDINGS OF FACT

On June 1, 1969, Nathaniel Garfield and Thomas McSherry formed McSherry Associates, LP (the partnership), a New York limited partnership...

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