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FLATT v. COMMISSIONER

Docket Nos. 8982-84, 13418-84.

52 T.C.M. 713 (1986)

T.C. Memo. 1986-495

Hollis B. Flatt and Judy F. Flatt v. Commissioner. James K. Bailey and Cleta Sue Bailey v. Commissioner.

United States Tax Court.

Filed September 30, 1986.

Attorney(s) appearing for the Case

William Robert Pope, Jr., 230 Fourth Ave., Nashville, Tenn., for the petitioners in docket No. 8982-84. John B. Owens, Jr., 200 Fourth Ave., Nashville, Tenn., for the petitioners in docket No. 13418-84. Nancy W. Hale, for the respondent.

Memorandum Opinion

GUSSIS, Special Trial Judge:

These consolidated cases were assigned pursuant to section 7456(d) of the Internal Revenue Code of 1954 and Rules 180, 181 and 182, Tax Court Rules of Practice and Procedure.1

Respondent determined the following deficiencies in income tax:

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