T.C. Memo. 2004-143
UNITED STATES TAX COURT
KEITH AND JANET SCHERBART, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3345-99. Filed June 17, 2004.
Kathryn J. Sedo and Ryan Kelly, for petitioners.
Blaine C. Holiday, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: Respondent determined
deficiencies of $3,791 and $2,582 in petitioners’ 1994 and 1995
Federal income taxes, 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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