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TOM v. COMMISSIONER

Docket No. 16512-99.

83 T.C.M. 1203 (2002)

T.C. Memo. 2002-36

Tom and Louise Kappus v. Commissioner.

United States Tax Court.

Filed February 8, 2002.

Attorney(s) appearing for the Case

Frank Joseph O'Connell, Jr., Oak Brook, Illinois, for the petitioners.

Jennifer L. Nuding, for the respondent.

MEMORANDUM OPINION

GOLDBERG, Special Trial Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $6,152 for the taxable year 1997. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The sole issue for decision is whether petitioners are subject to the limitations on the...

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