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WENZEL v. COMMISSIONER

Docket No. 29466-88.

61 T.C.M. 2396 (1991)

T.C. Memo. 1991-166

Fred W. Wenzel and Mary Wenzel v. Commissioner.

United States Tax Court.

Filed April 10, 1991.

Attorney(s) appearing for the Case

James D. Spratt, Jr., 1360 Peachtree St., N.E., Atlanta, Ga., for the petitioner. John W. Sheffield III, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency and an addition to tax in petitioners' Federal income tax as follows:

                                    Addition to Tax
Year                   Deficiency    Section 66611

1985 ...............      $42,123       $10,531

The issues for decision are:

(1) Whether petitioners...

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