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SCHULZE v. COMMISSIONER

Docket No. 8976-77.

40 T.C.M. 1234 (1980)

T.C. Memo. 1980-385

Herbert C. Schulze and Mary Jeanne Schulze v. Commissioner.

United States Tax Court.

Filed September 16, 1980.

Attorney(s) appearing for the Case

Herbert C. Schulze, pro se. Jeffrey L. Millward, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' income tax in the amount of $5,691.25 and an addition to tax under section 6651(a)(1), I.R.C. 1954 in the amount of $1,422.81 for the taxable year ended December 31, 1971.

As a result of concessions, the only issues for decision are: (1) The proper characterization of payments totaling $15,000 received by petitioner Herbert C. Schulze in connection...

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