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KELLEY v. COMMISSIONER

Docket No. 38523-84.

52 T.C.M. 313 (1986)

T.C. Memo. 1986-405

Daniel M. and Nancey N. Kelley v. Commissioner.

United States Tax Court.

Filed August 27, 1986.

Attorney(s) appearing for the Case

Arthur H. Boelter, 999 3rd Ave., Seattle, Wash., for the petitioners. Michael R. McMahon, for the respondent.

Memorandum Opinion

COHEN, Judge:

Respondent determined a deficiency of $240,839 in petitioners' 1980 Federal income taxes. After concessions by both parties, the sole issue for decision is whether section 6501(a)1 bars assessment of tax on an item reported on petitioners' 1980 tax return as their share of a small business corporation loss.

All of the facts have been stipulated...

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