-8- petitioners have conceded the issue of inclusion into income of both interest payments.6 Respondent’s determination on this issue is sustained. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent. 6 We note at the conclusion of the trial on Feb. 14, 2005, petitioners were directed to file a memorandum in response to respondent’s pretrial memorandum by Mar. 21, 2005. No such memorandum by petitioners was filed, and the record was ordered closed on Mar. 31, 2005.Page: Previous 1 2 3 4 5 6 7 8 9
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