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SEELBACH v. COMMISSIONER

Docket No. 33780-87.

58 T.C.M. 613 (1989)

T.C. Memo. 1989-600

Paul W. Seelbach and Arlene M. Seelbach v. Commissioner.

United States Tax Court.

Filed November 1, 1989.

Attorney(s) appearing for the Case

Paul T. Mengal, 7125 Orchard Lake Rd., West Bloomfield, Mich., for the petitioners. Dennis G. Driscoll, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In separate notices of deficiency respondent determined a deficiency of $2,133 in the 1984 income tax of petitioner, Paul W. Seelbach, and a deficiency of $3,318 in the 1985 income tax of petitioners, Paul W. Seelbach and Arlene M. Seelbach. The only issue for decision is whether certain payments received by petitioner, Paul W. Seelbach, are excludable from income under section 117

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