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LEROY v. COMMISSIONER

Docket No. 28440-82.

50 T.C.M. 1003 (1985)

T.C. Memo. 1985-469

Leroy D. and Mildred F. Ates v. Commissioner.

United States Tax Court.

Filed September 9, 1985.

Attorney(s) appearing for the Case

Leroy D. Ates, pro se, Abilene, Tex. Linda L. Wong, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency in the petitioners' Federal income tax of $3,571.65 for 1979. The issues for decision are: (1) Whether the petitioners may claim a miscellaneous deduction for amounts that they purportedly loaned to their children; and (2) whether the assessment and collection of the deficiency in income tax is barred by the statute of limitations.

Findings of Fact<...

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