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KISICKI v. COMMISSIONER

Docket No. 4409-85.

53 T.C.M. 819 (1987)

T.C. Memo. 1987-245

James P. Kisicki and Deborah A. Kisicki v. Commissioner.

United States Tax Court.

Filed May 11, 1987.

Attorney(s) appearing for the Case

Gerald W. Phillips, for the petitioners. Carol A. Szczepanik, for the respondent.

Memorandum Opinion

PATE, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d) (redesignated as sec. 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) and Rules 180, 181 and 182.1

Respondent determined deficiencies in petitioners' 1981 and 1982 Federal income taxes of $626.25 and $4,324.00, respectively. After concessions, the issues for our decision...

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