MICORESCU v. COMMISSIONER

Docket No. 24964-96.

76 T.C.M. 796 (1998)

T.C. Memo. 1998-398

Benjamin B. and Dorina Micorescu v. Commissioner.

United States Tax Court.

Filed November 10, 1998.


Attorney(s) appearing for the Case

Douglas G. Miller, Portland, Ore., for the petitioners. Ann M. Murphy, for the respondent.


MEMORANDUM OPINION

DEAN, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' Federal income taxes for the years 1992, 1993, and 1994 in the amounts of $2,222, $4,392, and $5,906, respectively.

After concessions by the parties,2 the issues for decision are: (1) Whether petitioners are entitled...

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