OWEN v. COMMISSIONER

Docket Nos. 41476-86, 13374-87, 18050-87, 18052-87, 32313-87, 37014-87, 39079-87.

59 T.C.M. 290 (1990)

T.C. Memo. 1990-172

Frank and Marianne Owen, et al. v. Commissioner.

United States Tax Court.

Filed March 29, 1990.


Attorney(s) appearing for the Case

Towner Leeper and John E. Leeper, 661 Mesa Hills, El Paso, Tex., for the petitioners. Phillip A. Pillar and Lewis J. Hubbard, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

The primary issues for decision are:

(1) Whether certain petitioners may amend their petitions to conform to the proof. We hold they may. (2) Whether the joint stipulation that a document is true and correct establishes as a fact the truth of the contents of the document. We hold it does not. (3) Whether petitioners may deduct their distributive shares of prepaid intangible...

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