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PAGLIARULO v. COMMISSIONER

Docket No. 12613-92.

68 T.C.M. 917 (1994)

T.C. Memo. 1994-506

Robert and Nancy Pagliarulo v. Commissioner.

United States Tax Court.

Filed October 12, 1994.

Attorney(s) appearing for the Case

Judah J. Rubin, for the petitioners. William T. Hayes and Robert M. Finkel, for the respondent.

Memorandum Opinion

NIMS, Judge:

Respondent determined a deficiency in Federal income tax with respect to petitioners' 1988 return in the amount of $34,296.15 and additions to tax in the amount of $12,243.94.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.

The issues for decision are:

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