T.C. Memo. 2007-363
UNITED STATES TAX COURT
JOSEPH M. AND MARJORIE SITA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10068-05. Filed December 10, 2007.
Joseph M. Sita, pro se.
Trent D. Usitalo, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined deficiencies in
petitioners’ Federal income taxes for 2001 and 2002 (years at
issue) of $3,121 and $2,100.1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and Rule references are to
the Tax Court Rules of Practice and Procedure. Amounts are
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