Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1987 in the amount of $12,759.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The sole issue before the Court is whether petitioner is taxable...
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