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OWENS v. COMMISSIONER

Docket No. 1999-78.

41 T.C.M. 1312 (1981)

T.C. Memo. 1981-193

Russell G. Owens, Jr., and Kay H. Owens v. Commissioner.

United States Tax Court.

Filed April 22, 1981.

Attorney(s) appearing for the Case

Stanley G. Barr, Jr., and R. Braxton Hill, III, for the petitioners. Michael R. Moore, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined a deficiency in petitioners' income tax for 1974 in the amount of $15,701.58. Respondent in his answer imposed upon petitioners a $7,850.79 addition to tax for 1974 under section 6653(b).1

Since petitioners failed to take exception to certain items of adjustment, the issues for decision are (1) the amount petitioners are entitled to deduct during...

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