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FIELDING v. COMMISSIONER

Docket No. 11518-89.

64 T.C.M. 796 (1992)

T.C. Memo. 1992-553

Morton D. Fielding and Jane A. Fielding v. Commissioner.

United States Tax Court.

Filed September 17, 1992.

Attorney(s) appearing for the Case

Winthrop Drake Thies, 15 N. Terrace, Maplewood, N.J., for the petitioners. William S. Garofalo and Patrick E. Whelan, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, by means of a statutory notice of deficiency, determined Federal income tax deficiencies of $11,234 and $1,087 for petitioners' 1980 and 1982 taxable years, respectively. The deficiencies are attributable to respondent's disallowance of tax benefits claimed in connection with Abbott Drilling Associates, a limited partnership. Respondent also determined...

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