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TEPPER v. COMMISSIONER

Docket No. 19518-88.

62 T.C.M. 505 (1991)

T.C. Memo. 1991-402

Jack Tepper and Rene Tepper v. Commissioner.

United States Tax Court.

Filed August 15, 1991.

Attorney(s) appearing for the Case

William R. Asbell, Jr., 260 Peachtree St., Atlanta, Ga., for the petitioners. Clinton M. Fried, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1978, 1979, and 1980 in the amounts of $16,176, $24,391, and $5,130, respectively.

The issues for decision are: (1) Whether petitioners were at risk during the years 1978 and 1979 in the amount of $30,000 pursuant to a document styled "Guaranty," executed by Jack Tepper on December 26, 1978, and (2) whether petitioners were...

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