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SMITHSI v. COMMISSIONER

Docket No. 10677-78.

42 T.C.M. 1638 (1981)

T.C. Memo. 1981-652

Thomas G. Smithsi and Roza Smithsi v. Commissioner.

United States Tax Court.

Filed November 9, 1981.

Attorney(s) appearing for the Case

Isidore R. Tucker, 50 Broadway, New York, N.Y., for the petitioners. Vincent R. Barrella, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1974 in the amount of $968.18.1 In contrast, petitioners claimed an overpayment of their 1974 taxes in the amount of $5,036. The issues for our decision are (1) whether petitioner Thomas G. Smithsi's transfer of $23,067.81 on October 26, 1976 to a purported Individual Retirement Account constituted...

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