Dean and Rosalie Monahan - Page 1
















                                 T.C. Memo. 2002-52                                   



                               UNITED STATES TAX COURT                                


                  DEAN MONAHAN AND ROSALIE MONAHAN, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16864-96.                February 25, 2002.                 


               Tobias Weiss, for petitioners.                                         
               Andrew M. Winkler, for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               SWIFT, Judge:  This case is before us on respondent’s motion           
          for entry of decision.  In an “affected-items” notice of                    
          deficiency, respondent determined additions to tax relating to              
          petitioners’ Federal income tax for 1982 as follows:                        








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