RATH v. COMMISSIONER

Docket Nos. 3984-92, 4017-92.

101 T.C. 196 (1993)

VIRGIL D. RATH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. JAMES R. SANGER AND MARJORIE F. SANGER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 8, 1993.


Attorney(s) appearing for the Case

Timothy G. Schally, for petitioners.

Mark J. Miller, for respondent.


OPINION

HAMBLEN, Chief Judge:

Respondent determined a deficiency of $15,000 in petitioner Virgil D. Rath's Federal income tax liability for the 1986 taxable year. In addition, respondent determined a deficiency of $48,999 in petitioners James R. Sanger and Marjorie F. Sanger's joint Federal income tax liability for the 1986 taxable year.

After concessions, the sole issue for decision is whether Virgil...

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