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GENNARO AND PATRICIA LABATO v. COMMISSIONER

Docket No. 4781-99.

82 T.C.M. 579 (2001)

T.C. Memo. 2001-243

Gennaro and Patricia Labato v. Commissioner.

United States Tax Court.

Filed September 18, 2001.

Attorney(s) appearing for the Case

Gennaro Labato, pro se. Ross M. Greenberg, for the respondent.

MEMORANDUM OPINION

PAJAK, Special Trial Judge.

Respondent determined a deficiency in petitioners' 1996 Federal income tax in the amount of $3,462 and a section 6651(a)(1) addition to tax in the amount of $866. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

As admitted by petitioners in the Stipulation of...

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