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SYNNESTVEDT v. COMMISSIONER

Docket No. 34794-83.

52 T.C.M. 1402 (1987)

T.C. Memo. 1987-31

John T. Synnestvedt and Marion Day Synnestvedt v. Commissioner.

United States Tax Court.

Filed January 14, 1987.

Attorney(s) appearing for the Case

Stephen E. Sokolic and John E. Kaskey, for the petitioners. James P. Clancy, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

Respondent has determined, by notice of deficiency dated September 16, 1983, a deficiency in petitioners' Federal income tax for the taxable year ended December 31, 1980, in the amount of $22,397, and by amended answer filed November 23, 1984, an increased deficiency, in the amount of $49,064.

After concessions, the primary issue remaining for decision is whether petitioners' sponsorship...

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