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MERKEL v. COMMISSIONER

Docket Nos. 10031-95, 10032-95.

109 T.C. 463 (1997)

DUDLEY B. AND LA DONNA K. MERKEL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT DAVID A. AND NANCY J. HEPBURN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 30, 1997.

Attorney(s) appearing for the Case

Gregory W. MacNabb, for petitioners.

Ann M. Welhaf, for respondent.

HALPERN, Judge:

In these consolidated cases, respondent determined deficiencies in the Federal income tax of petitioners Dudley and La Donna Merkel and David and Nancy Hepburn for their 1991 taxable (calendar) years in the amounts of $115,420 and $116,347, respectively. Both cases involve similar circumstances and require us to determine whether petitioners in the two cases (the Merkels and the Hepburns, respectively) may exclude under section 108(a)(1)(B)...

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