T.C. Memo. 1996-281
UNITED STATES TAX COURT
MAX M. AND JOAN E. GREENBERG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6843-94. Filed June 19, 1996.
Andrew M. Glatt, for petitioners.
Christine V. Olsen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined an $11,644 deficiency in
petitioners’ 1990 Federal income tax, and a $2,329 section 6662(a)
accuracy-related penalty for such year.
The principal issue for decision concerns the proper
characterization of payments petitioners received from or through
an entity known as Pioneer Mortgage in 1990 totaling $44,396 (viz,
whether said payments should be characterized as interest income,
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