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ROZPAD v. COMMISSIONER

Docket Nos. 6351-94, 6719-94.

74 T.C.M. 1264 (1997)

T.C. Memo. 1997-528

Joseph S. Rozpad and Kathleen M. Rozpad v. Commissioner. Floriano DiBiasio and Angela DiBiasio v. Commissioner.

United States Tax Court.

Filed November 24, 1997.

Attorney(s) appearing for the Case

Justin S. Holden, Providence, R.I., and Kimberly L. O'Brien, for the petitioners. Carmino J. Santaniello, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FOLEY, Judge:

Respondent issued notices of deficiency to Joseph and Kathleen Rozpad for their 1992 tax year and to Floriano and Angela DiBiasio for their 1989 tax year. The Rozpads and the DiBiasios each petitioned this Court in April of 1994. On April 1, 1997, we granted respondent's motion to consolidate the Rozpads' and the DiBiasios' cases.

Unless otherwise indicated, all section references are to the Internal...

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