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MICHAEL v. COMMISSIONER

Docket No. 7537-98.

78 T.C.M. 530 (1999)

T.C. Memo. 1999-333

Michael and Nancy McNamara v. Commissioner.

United States Tax Court.

Filed October 4, 1999.

Attorney(s) appearing for the Case

Garry A. Pearson and Jon J. Jenson, for the petitioners. Blaine C. Holiday, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PAJAK, Special Trial Judge:

Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $2,507, $3,191, and $2,963, for the taxable years 1993, 1994, and 1995, respectively. All section references are to the Internal Revenue Code in effect for the years in issue.

FINDINGS OF FACT

The sole issue for decision is whether rental payments received by petitioners from McNamara...

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