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WALLACE v. COMMISSIONER

Docket No. 9013-89.

62 T.C.M. 416 (1991)

T.C. Memo. 1991-378

R.D. and Louise Wallace v. Commissioner.

United States Tax Court.

Filed August 12, 1991.

Attorney(s) appearing for the Case

R.D. and Louise Wallace, pro se. Anthony S. Gasaway, 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 a deficiency of $3,606 in petitioners' 1985 Federal income tax and additions to tax of $180 under section 6653(a)(1) and 50 percent of the interest due on the deficiency under section 6653(a)(2).

The issues for decision are (1) whether petitioners are entitled to a...

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