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SMITH v. COMMISSIONER

Docket Nos. 17367-92, 17383-92.

68 T.C.M. 1538 (1994)

T.C. Memo. 1994-640

Ivan J. and Maxine Smith v. Commissioner. Robert J. and Bess L. Bell v. Commissioner.

United States Tax Court.

Filed December 29, 1994.

Attorney(s) appearing for the Case

James Benham, 1144 E. Jefferson St., Phoenix, Ariz., for the petitioners. J. Robert Cuatto and John R. Mikalchus, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

By separate notices of deficiency, respondent determined deficiencies in the 1989 Federal income taxes of Ivan J. and Maxine Smith (the Smiths) and Robert J. and Bess L. Bell (the Bells) in the respective amounts of $30,268 and $30,079. The Smiths and Bells are collectively referred to as petitioners.

The issues for decision arise out of Ivan Smith's (Smith) and Robert Bell's (Bell) involvement...

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