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JOHNSON v. COMMISSIONER

Docket No. 10839-99.

87 T.C.M. 971 (2004)

T.C. Memo. 2004-37

H. Dee Johnson, Jr., and Mary L. Johnson, n.k.a. Mary L. Alphin v. Commissioner.

United States Tax Court.

Filed February 17, 2004.

Attorney(s) appearing for the Case

H. Dee Johnson, Jr., pro se.

Donna B. Read, for the respondent.

MEMORANDUM OPINION

HALPERN, Judge:

Respondent has determined deficiencies in petitioners' Federal income taxes of $22,297 and $13,179 for 1994 and 1995, respectively (the audit years). The parties have settled or otherwise disposed of certain of the adjustments resulting in those determinations, and the only question remaining for decision is whether petitioner husband (petitioner) has available for use by him in the audit years a claimed $153,000 net operating...

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