Docket No. 19223-93.

72 T.C.M. 474 (1996)

T.C. Memo. 1996-392

Paul A. Rendina and Janet Mae Rendina v. Commissioner.

United States Tax Court.

Filed August 21, 1996.

Attorney(s) appearing for the Case

Joseph P. Alexander, J. Timothy Bender, and David G. Lambert, Cleveland, Ohio, for the petitioners. Jeffrey J. Erney, for the respondent.


BEGHE, Judge:

Respondent determined a deficiency of $35,934 in petitioners' 1988 Federal income tax, and additions to tax of $1,797 and $8,984, under sections 6653(a)(1) and 6661(a), respectively.1 The deficiency arose from respondent's determination that the distribution to petitioner2 of two condominium units by Wood Street Apartments, Inc. (WSAI) was a dividend...

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