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PREWITT v. COMMISSIONER

Docket No. 21313-93.

69 T.C.M. 1693 (1995)

T.C. Memo. 1995-24

George D. Prewitt, Jr., and Bettye A. Prewitt v. Commissioner.

United States Tax Court.

Filed January 18, 1995.

Attorney(s) appearing for the Case

George D. Prewitt, Jr., pro se. Horace Crump, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge.

This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Respondent determined a deficiency of $5,470 in petitioners' Federal income tax for 1991. At trial, respondent conceded one adjustment in the notice of deficiency, unreported interest income of $2,396. The issues for decision are: (1) Whether, under section 451(a), back pay awards received...

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