PRESCOTT v. COMMISSIONER

Docket No. 5432-82.

47 T.C.M. 1389 (1984)

T.C. Memo. 1984-157

Walter C. Prescott and Amelia J. Prescott v. Commissioner.

United States Tax Court.

Filed March 29, 1984.


Attorney(s) appearing for the Case

Joseph B. Alala, Jr. and J. Robert Wren, Jr., 192 South St., Gastonia, N.C., for the petitioners. Mathew E. Bates, for the respondent.


Supplemental Memorandum Opinion

KÖRNER, Judge:

The instant case was submitted to the Court on a fully stipulated set of facts pursuant to Rule 122.1 The sole issue presented by the parties to us for determination was whether petitioners received $21,000 of dividend income during 1978 which they failed to report in their return.

In its initial memorandum opinion herein, filed as T.C. Memo. 1983-709...

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