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COULTER v. COMMISSIONER

Docket No. 8689-82.

45 T.C.M. 505 (1983)

T.C. Memo. 1983-19

John A. and Doris L. Coulter v. Commissioner.

United States Tax Court.

Filed January 12, 1983.

Attorney(s) appearing for the Case

John A. Coulter, pro se. Sara W. Dalton, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent determined a deficiency of $2,133.72 in petitioners' Federal income tax for the year 1978 and an addition to tax of $106.68 under section 6653(a).1

At issue are (1) whether petitioners are entitled to a claimed Schedule C business loss and to income averaging for 1978; and (2) whether they are liable for the addition to tax under section 6653(a).

No facts have been...

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