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DIBLE v. COMMISSIONER

Docket Nos. 40734-86, 39228-87.

58 T.C.M. 556 (1989)

T.C. Memo. 1989-589

Leonard F. Dible and Barbara H. Dible v. Commissioner.

United States Tax Court.

Filed October 30, 1989.

Attorney(s) appearing for the Case

Jeffrey S. Dible, 200 Madison Ave., New York, N.Y., for the petitioners. Deborah M. Leonard, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By two notices of deficiency dated July 17, 1986, and December 7, 1987, respondent determined the following deficiencies in petitioners' Federal income tax:

  Year                          Deficiency

  1982 ........................ $34,686.00
  1983 ........................  32,167.00

After concessions, the remaining issue for decision is whether payments received...

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