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HINES v. COMMISSIONER

Docket No. 44931-86.

56 T.C.M. 1050 (1989)

T.C. Memo. 1989-17

Stanley T. Hines and Teddi B. Hines v. Commissioner.

United States Tax Court.

Filed January 10, 1989.

Attorney(s) appearing for the Case

Robert R. Ross, 1440 Parkside Ave., Trenton, N.J., for the petitioners. Daniel Morman, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

The issues for decision in this case are:

(1) Whether petitioners realized $45,000 of unreported income during taxable year 1979;

(2) If so, whether petitioners have, as a consequence, omitted more than 25 percent of gross income from their income tax return for 1979;

(3) If there was a more than 25-percent omission from gross income, whether petitioners have

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