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NICOLAI v. COMMISSIONER

Docket No. 20582-95.

73 T.C.M. 2157 (1997)

T.C. Memo. 1997-108

Hugo Madioni and Susanne J. Nicolai v. Commissioner.

United States Tax Court.

Filed March 3, 1997.

Attorney(s) appearing for the Case

Hugo Madioni Nicolai, pro se. D. Lyndell Pickett, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief 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 a deficiency in petitioners' 1992 Federal income tax in the amount of $1,120.

The only issue in dispute is whether petitioners are entitled to a deduction in the amount of $4,000 for contributions to their respective individual retirement accounts...

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