McKNIGHT v. COMMISSIONER

Docket No. 22859-88.

58 T.C.M. 1390 (1990)

T.C. Memo. 1990-69

Roy A. and Leola McKnight v. Commissioner.

United States Tax Court.

Filed February 13, 1990.


Attorney(s) appearing for the Case

John J. Collins, Jr. and Emily Cosner Tobias, 1400 N. Woodward Ave., Bloomfield Hills, Mich., for the petitioners. Thomas M. Rath, for the respondent.


Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $23,593 in petitioners' Federal income tax for 1985 and an addition to tax of $5,898 pursuant to section 6661.

Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

After a concession by respondent...

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