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O'MALLEY v. COMMISSIONER

Docket No. 28404-86.

91 T.C. 352 (1988)

THOMAS O'MALLEY AND RITA O'MALLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 25, 1988.

Attorney(s) appearing for the Case

Edward J. Calihan, Jr., and Patrick J. Calihan, for the petitioners.

William E. Bogner and Madlyn B. Coyne, for the respondent.

RUWE, Judge:

Respondent determined deficiencies in petitioners' 1981 and 1982 Federal income taxes in the amounts of $174,428.31 and $109,796.67, respectively. The issues for decision are: (1) Whether petitioner, Thomas O'Malley, received unreported income in the amounts of $266,280.55 and $212,212.34 for the taxable years 1981 and 1982, respectively, from the payment by Central States Pension Fund of his legal fees; (2) whether petitioner, Thomas O'Malley...

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