T.C. Memo. 2001-114
UNITED STATES TAX COURT
JOHN & CHRISTINA WADE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11521-99. Filed May 14, 2001.
Erwin A. Rubenstein, for petitioners.
Gregory C. Okwuosah, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: Respondent determined a
deficiency in petitioners’ Federal income tax of $1,120 for the
taxable year 1996. 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.
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