Max M. and Joan E. Greenberg - Page 1

                                 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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