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COHN v. COMMISSIONER

Docket No. 12520-79.

46 T.C.M. 286 (1983)

T.C. Memo. 1983-301

J. Bradley Cohn and Elizabeth R. Cohn v. Commissioner.

United States Tax Court.

Filed May 26, 1983.

Attorney(s) appearing for the Case

Michael D. Bray, 30 Rockefeller Plaza, New York, N.Y., for the petitioners Norman A. Segal, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

    Calendar
     Year            Deficiency

     1971 ........  $ 9,204.88
     1972 ........    7,412.73
     1973 ........    9,518.87
     1974 ........    9,543.46
     1975 ........   11,008.11

As a result of concessions made by petitioners, the sole issue remaining for decision is...

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