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RINK v. COMMISSIONER

Docket No. 20318-91.

100 T.C. 319 (1993)

THOMAS C. RINK AND ALISON W. RINK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 7, 1993.

Attorney(s) appearing for the Case

Thomas C. Rink, pro se.

James D. Hill, for respondent.

RUWE, Judge:

Respondent determined deficiencies of $8,118 and $4,983 in petitioners' Federal income taxes for 1985 and 1986, respectively. The issue we must decide is whether petitioners are precluded from claiming depreciation deductions for the taxable year 1986 as a result of a closing agreement executed by the parties in 1987.1

FINDINGS OF FACT

Some of the facts have...

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