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FERGUSON v. COMMISSIONER

Docket No. 26478-89.

64 T.C.M. 431 (1992)

T.C. Memo. 1992-451

Marian N. Ferguson and M. Carr Ferguson v. Commissioner.

United States Tax Court.

Filed August 10, 1992.

Attorney(s) appearing for the Case

Marian N. Ferguson and M. Carr Ferguson, pro se.

Steven R. Winningham, for the respondent.

Memorandum Findings of Fact and Opinion

WOLFE, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.1 Respondent determined a deficiency of $4,514 in petitioners Federal income tax for 1981.

After concessions, the sole issue with respect to petitioners' 1981 taxes is whether a restricted consent to extension of the period for assessment and collection permits...

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