Memorandum Opinion
WELLS, Judge:
The instant case is before us on respondent's motion for summary judgment. Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1988 in the amount of $5,357. Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioners resided in New York, New York, at the time they filed...
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