MIDDLETON v. COMMISSIONER

Docket No. 13937-79.

77 T.C. 310 (1981)

MILLEDGE L. MIDDLETON AND ESTATE OF LEONE S. MIDDLETON, DECEASED, MILLEDGE L. MIDDLETON, EXECUTOR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 10, 1981.


Attorney(s) appearing for the Case

Robert M. Fink, for the petitioners.

Mark W. Nickerson, for the respondent.


OPINION

NIMS, Judge:

In the statutory notice of deficiency, respondent determined deficiencies in petitioners' income tax for the years 1975 and 1976 in the respective amounts of $2,770.07 and $2,312.07. On June 17, 1980, this Court granted respondent leave to file an amendment to his answer, and, as a result, the deficiencies for 1975 and 1976 were increased to $3,895.30 and $3,924.15. The issues for decision are: (1) Whether petitioners' partnership...

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