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ALFONSO J. v. COMMISSIONER

Docket No. 1514-05.

92 T.C.M. 112 (2006)

T.C. Memo. 2006-165

Alfonso J. and Elena L. Diaz del Castillo v. Commissioner.

United States Tax Court.

August 14, 2006.

Attorney(s) appearing for the Case

Alfonso J. and Elena L. Diaz del Castillo, pro sese.

Scott A. Hovey, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a $2,327.40 deficiency in petitioners' 2001 Federal income tax. Respondent's determination was based on the disallowance of a deduction claimed on petitioners' 2001 joint Federal income tax return for an $8,448 charitable contribution carryover. Petitioners contend, alternatively, that they are not liable for the deficiency under any of the following three theories: (1) The statutory...

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