McKINNEY v. COMMISSIONER

Docket No. 5437-78.

42 T.C.M. 467 (1981)

T.C. Memo. 1981-377

Edith G. McKinney and Estate of James R. McKinney, Deceased, Edith G. McKinney, Executrix v. Commissioner.

United States Tax Court.

Filed July 27, 1981.


Attorney(s) appearing for the Case

James R. McKinney, pro se,1 3345 N.W. 22nd, Oklahoma City, Okla. Leroy D. Boyer, for the respondent.


Supplemental Memorandum Opinion

NIMS, Judge:

We have reexamined our conclusion as to the application of section 280A(c)(5)(B)2 relating to the deficiency for 1976. See McKinney v. Commissioner [Dec. 37,832(M)], T.C. Memo. 1981-181 (April 15, 1981). That issue was neither raised nor briefed by the parties, but has been the subject of full consideration in Bolton v. Commissioner<...

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