ROBERSON v. COMMISSIONER

Docket No. 24825-82.

52 T.C.M. 850 (1986)

T.C. Memo. 1986-520

Tom P. Roberson and Marlo D. Roberson v. Commissioner.

United States Tax Court.

Filed October 20, 1986.


Attorney(s) appearing for the Case

Richard P. Voss and Michael Weinstock, Atlanta, Ga., for the petitioners. Lourdes M. DeSantis, for the respondent.


Memorandum Opinion

CLAPP, Judge:

This matter is before the Court on petitioners' Motion for Partial Summary Judgment and respondent's Cross-Motion for Partial Summary Judgment pursuant to Rule 121.1

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

    Year                 Deficiency

  1976 ................. $22,847.00
  1977 .................  18,747.00
...

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