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LYLE v. COMMISSIONER

Docket No. 18428-97.

77 T.C.M. 2106 (1999)

T.C. Memo. 1999-184

John Allen and Glenna A. Lyle v. Commissioner.

United States Tax Court.

Filed June 7, 1999.

Attorney(s) appearing for the Case

John Allen Lyle and Glenna A. Lyle, pro sese. Gerald L. Brantley, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent, by means of a statutory notice of deficiency, determined a deficiency in petitioners' 1995 income tax of $8,938 and a section 6662(a)1 penalty of $1,788.

The issues for our consideration are: (1) Whether the correspondence in this case from respondent's employee estopped respondent from determining a deficiency in petitioners' 1995 Federal income tax;...

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