ALBERT v. COMMISSIONER

Docket No. 5808-77.

41 T.C.M. 591 (1980)

T.C. Memo. 1980-567

Kenneth D. Albert and Jewel B. Albert v. Commissioner.

United States Tax Court.

Filed December 18, 1980.


Attorney(s) appearing for the Case

Kenneth D. Albert, pro se. Michael R. Moore, for the respondent.


Memorandum Findings of Fact and Opinion

WILBUR, Judge:

The Commissioner determined deficiencies in petitioners' Federal income taxes for the taxable years 1973 and 1974 in the amounts of $2,057.08 and $490.85, respectively. Respondent having conceded certain adjustments, the following issues remain for our decision:

(1) Whether, for purposes of section 1374(a)1 and section 1374(c)(2), petitioners are entitled to increase...

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