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McCULLEN v. COMMISSIONER

Docket No. 7042-95.

73 T.C.M. 3106 (1997)

T.C. Memo. 1997-280

Allie Ray McCullen and Shurley G. McCullen v. Commissioner.

United States Tax Court.

Filed June 19, 1997.

Attorney(s) appearing for the Case

J. Wesley Casteen, for the petitioners. Amy Dyar Seals, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined that petitioners are liable for income tax deficiencies of $12,514 for 1990 and $7,386 for 1991. Respondent also determined that petitioners are liable for the accuracy-related penalty for negligence under section 6662(a) of $2,503 for 1990 and $1,477 for 1991.

After concessions, we must decide:

1. Whether petitioner Allie Ray McCullen had a trade or business of...

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