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NATIONAL TAX CONSULTANTS, INC. v. COMMISSIONER

Docket Nos. 4646-85, 4647-85.

52 T.C.M. 1529 (1987)

T.C. Memo. 1987-58

National Tax Consultants, Inc.; Lorraine T. Foster, Transferee of Assets of National Tax Consultants, Inc.; Karl L. Foster Financial Recovery Systems, Inc., Transferee of Assets of National Tax Consultants, Inc. v. Commissioner. Karl L. Foster v. Commissioner.

United States Tax Court.

Filed January 27, 1987.

Attorney(s) appearing for the Case

Karl L. Foster and Lorraine T. Foster, pro se. John W. Schmittdiel, for respondent.

Memorandum Opinion

DINAN, Special Trial Judge:

These cases were assigned pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. —) of the Code and Rules 180, 181 and 182.1 For convenience and clarity, the findings of fact and conclusions of law have been combined in this opinion.

Respondent determined a deficiency in...

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