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CHIAPPETTI v. COMMISSIONER

Docket No. 12534-94.

71 T.C.M. 2778 (1996)

T.C. Memo. 1996-183

Donald L. Chiappetti, and Mary K. Chiappetti v. Commissioner.

United States Tax Court.

Filed April 16, 1996.

Attorney(s) appearing for the Case

Robert Ong Hing and Gregory Ong Hing, Scottsdale, Ariz., for the petitioners. Ann M. Welhaf, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

Year                                 Deficiency

1990 .............................     $4,793
1991 .............................      9,618

The sole issue for decision is whether petitioners had gross income of $14,522 and $38,248 for 1990 and 1991, respectively, attributable...

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