J.B.S. ENTERPRISES, INC. v. COMMISSIONER

Docket No. 29624-89.

61 T.C.M. 2829 (1991)

T.C. Memo. 1991-254

J.B.S. Enterprises, Inc. v. Commissioner.

United States Tax Court.

Filed June 5, 1991.


Attorney(s) appearing for the Case

Rick K. Disney, 2902 Texas American Bk. Bldg., Fort Worth, Tex., for the petitioner. Steve Brower, for the respondent.


Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for its fiscal year ending April 30, 1986, in the amount of $13,148.28, and for its fiscal year ending April 30, 1987, in the amount of $12,506.40.

The issue for decision is whether payments made to Mary Schusler by petitioner, and payroll taxes paid on account of Mary Schusler, are

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