ELLIOTT v. COMMISSIONER

Docket No. 10175-85.

90 T.C. 960 (1988)

THOMAS O. AND CAROL J. ELLIOTT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 11, 1988.


Attorney(s) appearing for the Case

Wayne A. McFadden, for the petitioners.

Thomas R. Mackinson, for the respondent.


WRIGHT, Judge:

By a notice of deficiency dated January 24, 1985, respondent determined a deficiency of $7,825 in petitioner's 1981 Federal income taxes and additions to tax in the amounts of $590, $671, and 50 percent of the statutory interest due on $7,825 under sections 6651(a)(1), 6653(a)(1), and 6653(a)(2), respectively.

After concessions, the issues for our consideration are (1) whether petitioners' activities in 1981 with regard to an Amway distributorship...

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