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WILBOURN v. COMMISSIONER

Docket No. 15306-87.

57 T.C.M. 348 (1989)

T.C. Memo. 1989-222

Frank W. Wilbourn, Jr., and Betty K. Wilbourn v. Commissioner.

United States Tax Court.

Filed May 9, 1989.

Attorney(s) appearing for the Case

James T. Bland, Jr., 1900 One Commerce Square, Memphis, Tenn., for the petitioners. Rebecca A. Dance and Calder L. Robertson, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rule 180 et seq.1

In a notice of deficiency, respondent determined a deficiency in petitioners' Federal income tax for 1983 in the amount of $14,784.75. When the case was called for trial, the parties filed a Stipulation of Settlement in which respondent conceded...

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