SCHROTT v. COMMISSIONER

Docket No. 42603-86.

57 T.C.M. 981 (1989)

T.C. Memo. 1989-346

John D. Schrott and Estate of Winona W. Schrott, Deceased, John D. Schrott, Executor v. Commissioner.

United States Tax Court.

Filed July 19, 1989.


Attorney(s) appearing for the Case

Glenn J. Sedam, Jr., Edward S. Culbertson, and Joseph P. Spellman, for the petitioners. Diane D. Helfgott and Richard M. Marsh, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the years and in the amounts that follow:

Year                           Deficiency

1973 .......................     $ 12,100
1975 .......................       73,790
1976 .......................      100,755

After concessions, the issues for decision are: (1) Whether and to what extent...

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