ZUANICH v. COMMISSIONER

Docket No. 594-78.

77 T.C. 428 (1981)

PETER ZUANICH AND MARY ANN ZUANICH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 20, 1981.


Attorney(s) appearing for the Case

Peter Zuanich, pro se.

Matthew W. Stanley, for the respondent.


CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioners for 1975 in the amount of $7,736.85. The issues for decision are as follows:

(1) Whether respondent should be equitably estopped from disallowing a portion of petitioners' claimed foreign tax credit because of petitioner-husband's asserted reliance on advice understood by petitioner-husband as having been given to him by respondent's agents; and

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