Nicholas & Carrie Cozzens, (2005)

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Nicholas & Carrie Cozzens, (2005)

T.C. Memo. 2005-98

UNITED STATES TAX COURT NICHOLAS & CARRIE COZZENS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 258-03L. Filed May 4, 2005.

Nicholas and Carrie Cozzens, pro sese. Michelle M. Lippert, for respondent.

MEMORANDUM OPINION CHIECHI, Judge: This case is before the Court on respondent's motion for summary judgment (respondent's motion).1 We shall grant respondent's motion.

Background The record establishes and/or the parties do not dispute the following.2 On or about March 17, 2000, petitioners filed a Federal income tax (tax) return for each of their taxable years 1998 (1998 return) and 1999 (1999 return). In their 1998 return, petitioners reported, inter alia, total income of $76,031, taxable income of $63,308, total tax of $12,671, an...

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