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SMITH v. COMMISSIONER

Docket No. 1074-86.

53 T.C.M. 743 (1987)

T.C. Memo. 1987-226

Betty Smith and Estate of Bart Smith, Deceased, Betty Smith, Administratrix v. Commissioner.

United States Tax Court.

Filed May 4, 1987.

Attorney(s) appearing for the Case

David J. Simmons, 220 Market Ave. South, Canton, Ohio, for the petitioners. Susan M. Gray, for the respondent.

Memorandum Findings of Fact and Opinion

PATE, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d) (redesignated as sec. 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rules 180, 181 and 182.1

Respondent determined the following deficiencies in and additions to petitioners' Federal income and self-employment taxes:

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