BANEKATIS v. COMMISSIONER

Docket No. 46191-86.

56 T.C.M. 376 (1988)

T.C. Memo. 1988-474

John C. Banekatis v. Commissioner.

United States Tax Court.

Filed September 28, 1988.


Attorney(s) appearing for the Case

Edward Rappaport, 38 N. Main St., Gloversville, N.Y., for the petitioner. Gerald A. Thorpe and Karen A. Holmes, for the respondent.


Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined deficiencies of $1,183 and $4,952 in petitioner's 1983 and 1984 Federal income tax liability. After concessions, the sole issue for decision is whether petitioner's employment during 1983 and 1984 was temporary or indefinite.

Findings of Fact

Many of the facts have been stipulated, and the facts set forth in the stipulation and attached exhibits are incorporated...

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