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SCHWARTZ v. COMMISSIONER

Docket No. 2047-93.

70 T.C.M. 526 (1995)

T.C. Memo. 1995-415

Robert Schwartz and Peggy Ann Schwartz v. Commissioner.

United States Tax Court.

Filed August 24, 1995.

Attorney(s) appearing for the Case

Phil H. Leone, Red Bank, N.J., for the petitioners. William S. Garofalo and Frank A. Racaniello, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

BEGHE, Judge:

Respondent determined deficiencies of $72,436, $16,652, and $679 in petitioners' 1986, 1987, and 1988 Federal income taxes, respectively.

All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The term "petitioner" refers to Robert Schwartz.

On November 16, 1990, petitioners...

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