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RALPH E. v. COMMISSIONER

Dkt. No. 5092-04.

91 T.C.M. 762 (2006)

T.C. Memo. 2006-30

Ralph E. and Mildred E. Galyen v. Commissioner.

United States Tax Court.

February 22, 2006.

Attorney(s) appearing for the Case

Scott M. Estill and Stephanie F. Long, for petitioners.

Richard D. D'Estrada, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined deficiencies of $3,323, $3,556, and $3,126 in petitioners' Federal income tax for 2000, 2001, and 2002, respectively.

The issues for decision are:

(1) Whether petitioners are entitled to claim a tax credit pursuant to sections 381 and 44 for their subscription to the AdaCom program (program);

(2) whether petitioners are entitled...

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