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YOUNGER v. COMMISSIONER

Docket No. 11057-78.

40 T.C.M. 1354 (1980)

T.C. Memo. 1980-421

Bryson R. Younger and Dorothy H. Younger v. Commissioner.

United States Tax Court.

Filed September 23, 1980.

Attorney(s) appearing for the Case

Bryson R. Younger, pro se. Paul K. Voelker, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined a deficiency for petitioners' calendar year 1975 in their income tax in the amount of $105 and in the excise tax imposed by section 4973, I.R.C. 1954,1 in the amount of $23.10. At the trial, petitioners conceded the income tax deficiency of $105, leaving for our decision only whether petitioners are liable for the 6 percent excise tax imposed by section 4973.

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