GAINES v. COMMISSIONER

Docket Nos. 8305-78, 8306-78, 8307-78, 8308-78, 8309-78.

45 T.C.M. 363 (1982)

T.C. Memo. 1982-731

Billy J. Gaines and Martha C. Gaines, et al. v. Commissioner.

United States Tax Court.

Filed December 21, 1982.


Attorney(s) appearing for the Case

S. Ralph Gordon and H. Jere Ford, 1000 Fidelity Federal Bldg., Nashville, Tenn., for the petitioners. Shuford A. Tucker, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

                         Calendar Year
                         or Date Fiscal
      Petitioners          Year Ends          Amount

  Billy J. Gaines and
  Martha C. Gaines
  (docket No. 8305-78)       1973 ........   $2,234.66

  Lewis E. Gaines, Jr. and
  Jackie Gaines
  (docket No. 8306-78) ...

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