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LOWERS v. COMMISSIONER

Docket No. 1694-90.

61 T.C.M. 1971 (1991)

T.C. Memo. 1991-75

Cassius C. Lowers, Jr. and Mary J. Lowers v. Commissioner.

United States Tax Court.

Filed February 27, 1991.

Attorney(s) appearing for the Case

Wylie Joseph Neal, for the petitioners. C. Glenn McLoughlin, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3)1 and Rule 180 et seq.

Respondent determined deficiencies of $4,981 and $2,936 in Federal income taxes, respectively, for petitioners' 1985 and 1986 tax years. The only issue for decision is whether certain payments received by Cassius C. Lowers, Jr. (petitioner) during 1985 and 1986 constituted capital gains within...

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