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WRAY v. COMMISSIONER

Docket No. 2253-77.

37 T.C.M. 1849 (1978)

T.C. Memo. 1978-488

Robert D. Wray and Barbara D. Wray; and Kirk I. Pierce and Sandra Pierce v. Commissioner.

United States Tax Court.

Filed December 11, 1978.

Attorney(s) appearing for the Case

Michel G. Emmanuel and J. Baird Lefter, Exchange National Bank Bldg., Tampa, Fla., for the petitioners. Lewis J. Hubbard, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

Petitioners              Year    Deficiency

Robert D. Wray and
  Barbara D. Wray        1973    $37,543.93
Kirk I. Pierce and
  Sandra Pierce          1972     10,376.85

The issues for decision are:

(1) Whether respondent is barred by the statute of limitations from assessing any income...

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