Docket No. 5069-94.

72 T.C.M. 594 (1996)

T.C. Memo. 1996-408

John A. Malone and Brenda K. Malone v. Commissioner.

United States Tax Court.

Filed September 9, 1996.

Attorney(s) appearing for the Case

Jill E. Bliss, Seattle, Wash., for the petitioners. William McCarthy and Keith Medleau, for the respondent.*


COLVIN, Judge:

Respondent determined that petitioners had deficiencies in Federal income tax of $8,276 for 1989, $21,265 for 1990, and $1,901 for 1991.

Petitioners bought all of the stock of Seattle Pump Company, Inc. (Seattle Pump). They gave the seller a note secured by letters of credit. The letters of credit were secured in part by a deed of trust on petitioners' residence. Seattle Pump employed petitioner...

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