T.C. Memo. 2003-342
UNITED STATES TAX COURT
PAUL S. AND SHARON E. TALCHIK, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12419-02. Filed December 16, 2003.
Paul S. and Sharon E. Talchik, pro se.
Leonard T. Provenzale, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined a
deficiency of $13,974 in petitioners' Federal income tax for
1999.1
1 Unless otherwise indicated, all section references
hereafter are to the Internal Revenue Code in effect for the year
at issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. The petition was filed pursuant to sec.
7463. At trial, pursuant to Rule 171(c), petitioners moved,
(continued...)
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