SCHOCH v. COMMISSIONER

Docket No. 18786-89.

62 T.C.M. 1135 (1991)

T.C. Memo. 1991-547

Eric P. Schoch and Anette K. Schoch v. Commissioner.

United States Tax Court.

Filed November 4, 1991.


Attorney(s) appearing for the Case

Harvey D. Tack, 2049 Century Park East, Los Angeles, Calif., for the petitioners. Marilyn Devin and Joseph K. Fletcher III, for the respondents.


Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

Respondent determined a deficiency of $534,836 in petitioners' Federal income tax for the taxable year 1988. The issues for decision are: (1) Whether petitioners failed to report gross income in the amount of $1,990,858 from the sales and exchanges of gold and platinum coins in 1988; and (2) whether petitioner Anette K. Schoch is entitled to relief as an innocent spouse pursuant to section 6013(e).

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