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POPOV v. COMMISSIONER

Docket No. 24453-96.

76 T.C.M. 695 (1998)

T.C. Memo. 1998-374

Katia V. and Peter Popov v. Commissioner.

United States Tax Court.

Filed October 15, 1998.

Attorney(s) appearing for the Case

Peter Popov, for the petitioners. Daniel M. Whitley, for the respondent.

MEMORANDUM OPINION

NAMEROFF, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.1 Respondent determined a deficiency in petitioners' 1993 Federal income tax in the amount of $2,079 and an accuracy-related penalty under section 6662(a) in the amount of $416.

After concessions by respondent,2 the issues for decision are: (1...

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