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KEATING v. COMMISSIONER

Docket No. 21172-91.

69 T.C.M. 2052 (1995)

T.C. Memo. 1995-101

Keith and Pia Keating v. Commissioner.

United States Tax Court.

Filed March 13, 1995.

Attorney(s) appearing for the Case

John O'Shea, 305 Mill Spring Rd., Manhasset, N.Y., for the petitioners. William J. Gregg and Mark A. Ericson, for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' 1985 and 1986 Federal income taxes in the amounts of $4,274 and $4,445, respectively. After a concession by petitioners,2 the issues are: (1) Whether a portion of income received...

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