T.C. Memo. 1999-84
UNITED STATES TAX COURT
MICHAEL B. STREIFF AND LAUREN D. STREIFF, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12017-97. Filed March 23, 1999.
Felix S. Jacob, for petitioners.
Helen F. Rogers, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
183.1
Respondent determined a deficiency in petitioners' 1993
Federal income tax in the amount of $2,213. The sole issue is
whether certain amounts received by petitioners qualify for
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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