T.C. Memo. 2002-36
UNITED STATES TAX COURT
TOM AND LOUISE KAPPUS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16512-99. Filed February 8, 2002.
Frank Joseph O’Connell, Jr., for petitioners.
Jennifer L. Nuding, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: Respondent determined a
deficiency in petitioners’ Federal income tax in the amount of
$6,152 for the taxable year 1997. 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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