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DOMBROWSKI v. COMMISSIONER

Docket No. 10871-78.

40 T.C.M. 697 (1980)

T.C. Memo. 1980-261

Gregory T. Dombrowski and Sandra Dombrowski v. Commissioner.

United States Tax Court.

Filed July 21, 1980.

Attorney(s) appearing for the Case

Gregory T. Dombrowski, pro se. Joseph R. Peters, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $2,278 in petitioners' Federal income tax for 1975 together with an addition to tax under section 6653(a)1 in the amount of $114.

The issues for decision are as follows:

1. Whether an agreement whereby petitioners purportedly conveyed their lifetime services to a trust is effective to relieve them of...

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