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SUTHERLAND v. COMMISSIONER

Docket No. 15174-99.

81 T.C.M. 1001 (2001)

T.C. Memo. 2001-8

Penny J. Sutherland v. Commissioner.

United States Tax Court.

Filed January 19, 2001.

Attorney(s) appearing for the Case

Daniel C. Ertel, for the petitioner.

Robin L. Peacock, for the respondent.

MEMORANDUM OPINION

JACOBS, Judge:

This case is before the Court fully stipulated. See Rule 122. Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.

Respondent determined a $3,656 deficiency in petitioner's 1997 Federal income tax; this determination is based on respondent's disallowance of petitioner's claim for an earned...

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