Docket No. 20718-94.

72 T.C.M. 1470 (1996)

T.C. Memo. 1996-539

S. Clark Jenkins and Mary P. Jenkins v. Commissioner.

United States Tax Court.

Filed December 12, 1996.

Attorney(s) appearing for the Case

Randolph G. Abood, New York, N.Y., for the petitioners. Mary Ann Amodeo and Louis A. Ramunno, for the respondent.


CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

Year                         Deficiency

1990 .....................     $3,100
1991 .....................      9,329

After concessions by the parties, the issues for decision are:

(1) Whether payments made to North Carolina and Virginia resulting from deficiencies in fertilizer...

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