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D'AMICO v. COMMISSIONER

Docket No. 20087-97.

78 T.C.M. 783 (1999)

T.C. Memo. 1999-374

Salvatore J. D'Amico and Shirley E. D'Amico v. Commissioner.

United States Tax Court.

Filed November 10, 1999.

Attorney(s) appearing for the Case

Salvatore J. D'Amico, pro se. Stephen C. Best, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined a deficiency of $10,695 in petitioners' Federal income tax for 1994. The issue for decision is whether petitioners are entitled for 1994 to exclude certain amounts from their gross income under section 104(a).1 We hold that they are not.

FINDINGS OF FACT

Some of the facts have been...

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