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PRESSON v. COMMISSIONER

Docket No. 2900-86.

55 T.C.M. 753 (1988)

T.C. Memo. 1988-191

Norman A. Presson and Doris J. Presson v. Commissioner.

United States Tax Court.

Filed May 3, 1988.

Attorney(s) appearing for the Case

Charles F. Murray, from the petitioners. Edsel Ford Holman, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986.1

In a notice of deficiency dated November 1, 1985, respondent determined a $1,087 deficiency in petitioners' 1982 Federal income tax and a $1,890 deficiency in petitioners' 1983 Federal income tax. After a concession by

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