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McENEANY v. COMMISSIONER

Docket No. 3010-84.

52 T.C.M. 366 (1986)

T.C. Memo. 1986-413

Joseph K. McEneany v. Commissioner.

United States Tax Court.

Filed September 3, 1986.

Attorney(s) appearing for the Case

Duane D. Conover, for the petitioner. Michael Phalin and James Kamman, for the respondent.

Memorandum Findings of Fact and Opinion

BUCKLEY, Special Trial Judge:

The proceedings in this case were conducted pursuant to section 7456(d)(3) of the Code,1 and Rules 180, 181 and 182, Tax Court Rules of Practice and Procedure.2

In a statutory notice of deficiency dated November 10, 1983, respondent determined a deficiency in petitioner's 1982 Federal income tax of $2,255. The sole issue...

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