T.C. Memo. 2002-150
UNITED STATES TAX COURT
STEPHEN AND SARA GALLIGAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7094-00. Filed June 13, 2002.
Stephen Galligan and Sara Galligan, pro sese.
Blaine C. Holiday, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: Respondent determined
deficiencies in petitioners’ Federal income tax in the amounts of
$2,293 and $1,815 for the taxable years 1996 and 1997,
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.
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