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PETERS v. COMMISSIONER

Docket No. 9920-77.

37 T.C.M. 941 (1978)

T.C. Memo. 1978-219

Garry L. and Louise E. Peters v. Commissioner.

United States Tax Court.

Filed June 12, 1978.

Attorney(s) appearing for the Case

Charles L. Abrahams, Mt. Helix Dr., LaMesa, Calif., for the petitioners. Arthur A. Oshiro, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $3,502.00 in the petitioners' Federal income tax for 1972. The only issue for decision is whether the Commissioner has carried his burden of proving that the petitioners executed consents extending the statute of limitations in this case.

Some of the facts were stipulated, and those facts are so found.

The petitioners, Garry L. and Louise E. Peters, maintained...

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