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TETZ v. COMMISSIONER

Docket No. 458-88.

58 T.C.M. 1211 (1990)

T.C. Memo. 1990-26

Emmett L. Tetz and D. Laurie Tetz v. Commissioner.

United States Tax Court.

Filed January 16, 1990.

Attorney(s) appearing for the Case

Robert S. Wrinkle, for the petitioners.1 Thomas M. Rohall, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

For petitioners' 1984 taxable year, respondent determined a $23,690 deficiency in Federal income tax and additions to tax of $3,682.77 and $5,922.50 under sections 6651(a)(1)2 and 6661, respectively. After concessions3 of the parties, the issues remaining for our consideration are: (1) Whether petitioners' yacht chartering activity was an activity...

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