Daniel L. Fa'asamala and Yvette S. Fa'asamala - Page 5

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          constitute income to them.  Accordingly, respondent's                       
          determination of a $10,603 income tax deficiency for petitioners’           
          1995 taxable year is sustained.                                             
               To reflect the foregoing,                                              
                                             Decision will be entered for             
                                        respondent as to the income tax               
                                        deficiency.                                   


































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