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PEOPLES LOAN & TRUST CO. v. COMMISSIONER

Docket Nos. 30402-84, 30420-84.

89 T.C. 896 (1987)

PEOPLES LOAN & TRUST CO., AS POSSESSOR OF CERTAIN CASH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LEON E. HENDRICKSON, AS POSSESSOR OF CERTAIN CASH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 26, 1987.

Attorney(s) appearing for the Case

Robert E. Johnson, Marc A. Hetzner, and Linda S. Nichols, for the petitioners.1

Rodney J. Bartlett, for the respondent.

KÖRNER, Judge:

In these consolidated cases, the Commissioner determined that petitioner Peoples Loan & Trust Co., as possessor of certain cash, had a deficiency in Federal income tax of $113,250 for 1983, and that petitioner Leon E. Hendrickson, as possessor of certain cash, had a deficiency in Federal income tax of $1,834,500.25 for 1983. The issue for our decision is whether petitioners are liable for such deficiencies under section 6867 of the Internal...

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