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SIMON v. COMMISSIONER

Docket No. 4817-92.

103 T.C. 247 (1994)

RICHARD L. SIMON AND FIONA SIMON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 22, 1994.

Attorney(s) appearing for the Case

Arthur Pelikow, Norman Gold, and Milton Sherman, for petitioners.

Pamela L. Cohen, Paulette Segal, and Kevin Kilduff (specially recognized), for respondent.

LARO, Judge:

Richard Simon and Fiona Simon petitioned the Court for a redetermination of respondent's determinations in a notice of deficiency issued to them on December 11, 1991. In the notice respondent determined a $21,198 deficiency in petitioners' 1989 Federal income tax and a $4,240 addition thereto under section 6662(a) of the Internal Revenue Code in effect for 1989. Unless otherwise indicated, section references are to the Internal Revenue Code in...

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