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RUDZIN v. COMMISSIONER

Docket No. 21754-93.

69 T.C.M. 1649 (1995)

T.C. Memo. 1995-13

Bryna G. Rudzin v. Commissioner.

United States Tax Court.

Filed January 12, 1995.

Attorney(s) appearing for the Case

Peter Driscoll, 10320 Little Patuxent Pkwy., Columbia, Md., for the petitioner. Diane D. Helfgott, for the respondent.

Memorandum Findings of Fact and Opinion

CHIECHI, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for 1990 in the amount of $9,509 and an accuracy-related penalty under section 6662(a)1 in the amount of $1,902.

The issues remaining for decision are:

(1) Did petitioner have gross income for 1990 as a result of having received in that year a distribution pursuant to a qualified domestic...

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