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ALANIS v. COMMISSIONER

Docket No. 3184-93.

69 T.C.M. 2900 (1995)

T.C. Memo. 1995-263

Jose Alanis and Lidia Alanis v. Commissioner.

United States Tax Court.

Filed June 14, 1995.

Attorney(s) appearing for the Case

Jose Alanis and Lidia Alanis, pro se. Gerald L. Brantley, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1989 in the amount of $15,376.97 and an addition to tax under section 6662(a)1 in the amount of $3,000.79.

The issues for decision are: (1) Whether respondent's notice of deficiency was arbitrary. We hold it was not. (2) Whether petitioners had unreported income for the tax year 1989. We hold...

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