Docket No. 7462-94.

72 T.C.M. 139 (1996)

T.C. Memo. 1996-325

R. Edwin Brown and Winsome S. Brown v. Commissioner.

United States Tax Court.

Filed July 17, 1996.

Attorney(s) appearing for the Case

Rex L. Sturn, Rockville, Md., for the petitioners. Lindsey D. Stellwagen, for the respondent.


PARR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1990 in the amount of $179,597 and an accuracy-related penalty under section 6662(a)1 in the amount of $35,919.

The issues for decision are: (1) Whether the amount of debt outstanding on certain computer equipment contributed to the Barnesville School is includable in the amount...

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