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BROWN v. COMMISSIONER

Docket No. 347-78.

39 T.C.M. 442 (1979)

T.C. Memo. 1979-443

Willie James Brown and Linda R. Brown v. Commissioner.

United States Tax Court.

Filed November 6, 1979.

Attorney(s) appearing for the Case

James E. Caldwell, 8746 S. Blackstone, Chicago, Ill., for the petitioners. Mitchell S. Fuerst, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By letter dated October 13, 1977, respondent determined a deficiency in petitioners' income taxes paid for their taxable year ended December 31, 1975 in the amount of $937.81. The primary issue for our decision herein is whether respondent timely raised section 183 as authority to support his claimed deficiency.1

Findings...

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