T.C. Memo. 1997-273
UNITED STATES TAX COURT
GRANT K. HAGESTAD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14920-95. Filed June 17, 1997.
Jon T. Flask, for petitioner.
Warren P. Simonsen, for respondent.
MEMORANDUM OPINION
TANNENWALD, Judge: Respondent determined a deficiency of
$123,586.00 in petitioner's Federal income tax for the 1987
taxable year, and increased interest under section 6621(c)1 of
$31,027. After concessions by the parties, the issue for
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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