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MARRIOTT v. COMMISSIONER

Docket No. 2920-64.

25 T.C.M. 477 (1966)

T.C. Memo. 1966-86

Richard H. Marriott and Alice H. Y. Marriott v. Commissioner.

United States Tax Court.

Filed April 22, 1966.

Attorney(s) appearing for the Case

Joseph W. Trundle, 171 Culpeper St., Warrenton, Va., for the petitioners. Robert E. Garfield, for the respondent.

Memorandum Findings of Fact and Opinion

KERN, Judge:

Respondent has determined a deficiency in the Federal income tax liability of petitioners for the year 1961 in the sum of $140.98. Petitioners allege that they are entitled to a refund of an overpayment in the amount of $355.99. In a statement attached to his determination respondent has given the following explanation:

It has been determined that the amount of $1,462.73, claimed for premiums...

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