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SPERLING v. COMMISSIONER

Docket Nos. 6112-79, 15025-79.

45 T.C.M. 193 (1982)

T.C. Memo. 1982-681

Herbert L. Sperling and Janice Sperling v. Commissioner.

United States Tax Court.

Filed November 23, 1982.

Attorney(s) appearing for the Case

Thomas A. Condon, 20 Squadron Blvd., New York, N.Y., for the petitioners. Vincent R. Barrella, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:*

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Year                       Deficiency

  1974 ..................    $4,650.09
  1975 ..................     9,739.02
  1976 ..................     8,473.00

The issues for decision are whether payments of (1) college expenses or (2) insurance premiums pursuant...

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