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OMERZA v. COMMISSIONER

Docket No. 24138-90.

63 T.C.M. 2690 (1992)

T.C. Memo. 1992-206

Leroy J. Omerza and Betty J. Omerza v. Commissioner.

United States Tax Court.

Filed April 6, 1992.

Attorney(s) appearing for the Case

Mark E. Gammons, 22255 Center Ridge Rd., Rocky River, Ohio, for the petitioners. Dawn M. Krause, for the respondent.

Memorandum Opinion

BEGHE, Judge:

Respondent determined a deficiency of $11,782 in petitioners' Federal income tax for the year 1986. Respondent also determined that petitioners were liable for additions to tax under sections 6653(a)(1)(A) and (B), and 6661(a).1

This matter is before the Court on cross-motions for partial summary judgment.2 The issue for decision is whether petitioners are...

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