WARE v. COMMISSIONER

Docket No. 3890-87.

57 T.C.M. 105 (1989)

T.C. Memo. 1989-165

R. Timmis Ware and Catherine K. Ware v. Commissioner.

United States Tax Court.

Filed April 13, 1989.


Attorney(s) appearing for the Case

John P. Zampino, 600 3rd Ave., New York, N.Y., for the petitioners. Drita Tonuzi, for the respondent.


Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1982 in the amount of $31,969. In addition, respondent determined an addition to tax under section 66611 in the amount of $3,197. The issues for decision are whether petitioners realized $95,3072 of ordinary income during the year in issue as a result of R. Timmis Ware's...

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