BROWN v. COMMISSIONER

Docket No. 15981-84.

51 T.C.M. 1171 (1986)

T.C. Memo. 1986-239

Bruce and Joanne Brown v. Commissioner.

United States Tax Court.

Filed June 12, 1986.


Attorney(s) appearing for the Case

Towner S. Leeper and David Leeper, 661 Mesa Hills, El Paso, Tex., for the petitioners. David W. Johnson, for the respondent.


Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $194,326, and an addition to tax under section 6653(b)1 against petitioner Bruce Brown in the amount of $98,424 for the taxable year ended December 31, 1978.

The issues presented for decision are: (1) Whether the period of assessment of the tax due for petitioners' taxable...

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