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PETERS v. COMMISSIONER

Docket No. 8894-92.

65 T.C.M. 2948 (1993)

T.C. Memo. 1993-259

Harvey W. Peters v. Commissioner.

United States Tax Court.

Filed June 14, 1993.

Attorney(s) appearing for the Case

Harvey W. Peters, pro se. Abbey B. Garber, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge.

This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Respondent determined a deficiency in petitioner's 1989 Federal income tax of $1,251 and an addition to tax under section 6662(b)(1) of $104.

The issues for decision are: (1) Whether dividends received and capital gains realized constitute income from a trade or business activity...

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