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FRANK v. COMMISSIONER

Docket No. 1164-94.

71 T.C.M. 2748 (1996)

T.C. Memo. 1996-177

Andrew Wesley Frank and Joy Mary Frank v. Commissioner.

United States Tax Court.

Filed April 11, 1996.

Attorney(s) appearing for the Case

Andrew Wesley Frank and Joy Mary Frank, pro se. Kathryn K. Vetter, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax of $51,944 for 1991 and $12,672 for 1992 and accuracy-related penalties of $10,389 for 1991 and $2,534 for 1992.

After concessions, the issues for decision are:

1. Whether petitioners are exempt from Federal income tax. We hold that they are not.

2. Whether petitioners may deduct advertising expenses for selling...

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