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SWARTLING v. COMMISSIONER

Docket No. 36647-86.

54 T.C.M. 783 (1987)

T.C. Memo. 1987-506

Rodney D. Swartling and Jean E. Swartling v. Commissioner.

United States Tax Court.

Filed September 29, 1987.

Attorney(s) appearing for the Case

Thomas G. Walker, Jr., 184 Second St., Twin Falls, Idaho, for the petitioners. Cathy Campbell, for the respondent.

Memorandum Opinion

PETERSON, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d) of the Code (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755), and Rules 180, 181 and 182.1

Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $6,452. After concessions...

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