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WALDEN v. COMMISSIONER

Docket No. 46097-86.

55 T.C.M. 332 (1988)

T.C. Memo. 1988-98

Paul S. Walden and Marie C. Walden v. Commissioner.

United States Tax Court.

Filed March 7, 1988.

Attorney(s) appearing for the Case

John H. Birkeland, 1700 Lincoln St., Denver, Colo., for the petitioners. Linda J. Wise, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

This case was considered pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.1

Respondent determined a deficiency of $45,917 in petitioners' Federal income tax for the year 1980. Respondent has before the Court a motion for partial summary judgment...

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