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Scherbart v. Commissioner

Docket No. 3345-99.

87 T.C.M. 1418 (2004)

T.C. Memo. 2004-143

Keith and Janet Scherbart v. Commissioner.

United States Tax Court.

June 17, 2004.

Attorney(s) appearing for the Case

Kathryn J. Sedo and Ryan Kelly, for petitioners.

Blaine C. Holiday, for respondent.

MEMORANDUM OPINION

PAJAK, Special Trial Judge:

Respondent determined deficiencies of $3,791 and $2,582 in petitioners' 1994 and 1995 Federal income taxes, respectively. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After resolution of other issues as a result of Bot v. Commissioner [2004-1 USTC ...

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