Docket No. 23323-94.

72 T.C.M. 1344 (1996)

T.C. Memo. 1996-522

Ernest L. and Kathleen Newsome v. Commissioner.

United States Tax Court.

Filed November 26, 1996.

Attorney(s) appearing for the Case

James L. Robertson, Arlington, Tex., for the petitioners. Alvin A. Ohm, for the respondent.


CARLUZZO, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined deficiencies in petitioners' 1991 and 1992 Federal income taxes in the amounts of $5,256 and $5,169, respectively.

The issue for decision is whether petitioners underreported gross receipts from a newspaper delivery service business conducted by Ernest...

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