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VILLARROEL v. COMMISSIONER

Docket No. 12618-97.

76 T.C.M. 43 (1998)

T.C. Memo. 1998-247

Herman E. and Sheri L. Villarroel v. Commissioner.

United States Tax Court.

Filed July 6, 1998.

Attorney(s) appearing for the Case

Herman E. Villarroel and Sheri L. Villarroel, pro sese. Matthew J. Fritz, for the respondent.

MEMORANDUM OPINION

DINAN, 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' Federal income tax for 1994 in the amount of $2,327.

The issues for decision are: (1) Whether petitioners are required to include in their gross income any amount of a distribution from a qualified stock bonus plan...

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