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CUNNINGHAM v. COMMISSIONER

Docket No. 22176-93.

71 T.C.M. 2527 (1996)

T.C. Memo. 1996-141

Joseph Francis Cunningham v. Commissioner.

United States Tax Court.

Filed March 20, 1996.

Attorney(s) appearing for the Case

Kathleen A. Chapman, for the petitioner. Aretha Jones, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CARLUZZO, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined deficiencies in petitioner's 1987, 1988, and 1989 Federal income taxes in the amounts of $3,437, $1,093, and $4,634, respectively. The issue for decision is whether the limitations imposed by section 280A(c)(5) are applicable to...

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