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MICHAEL v. COMMISSIONER

Docket No. 17799-90.

64 T.C.M. 493 (1992)

T.C. Memo. 1992-461

Michael C. and Kathryn Lytle v. Commissioner.

United States Tax Court.

Filed August 17, 1992.

Attorney(s) appearing for the Case

Martin Silver, for the petitioners. John Altman, for the respondent.

Memorandum Findings of Fact and Opinion

BUCKLEY, Special Trial Judge:

This fully stipulated case was assigned pursuant to the provisions of section 7443A(b)(3)1 and Rules 180, 181 and 182. Respondent determined deficiencies in petitioners' 1985 and 1986 Federal income taxes in the amounts of $3,988 and $2,088 respectively. The only issue for decision is whether petitioner Michael C. Lytle's net earnings as a commercial fisherman...

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