-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.
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