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STRUCK v. COMMISSIONER

Dkt. No. 7900-05.

93 T.C.M. 928 (2007)

T.C. Memo. 2007-42

Myron R. Struck and Thelma C. Struck v. Commissioner.

United States Tax Court.

February 22, 2007.

Attorney(s) appearing for the Case

David S. Greenberg, for petitioners.

Joseph P. Wilson, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

Respondent determined deficiencies in and penalties on petitioners' Federal income taxes as follows:

   Year    Deficiency     Sec. 6662 Penalty

   2001     $27,555            $5,511
   2002       6,790             1,358

After concessions by the parties, the primary issue for decision is whether petitioners qualify for the foreign earned income exclusion...

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