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SCHMITT v. COMMISSIONER

Docket No. 22670-95.

76 T.C.M. 147 (1998)

T.C. Memo. 1998-269

Michael A. and Karyn E. Schmitt v. Commissioner.

United States Tax Court.

Filed July 23, 1998.

Attorney(s) appearing for the Case

Lawrence M. Lebowsky, for the petitioners. Michelle Or, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax in 1990 and 1991 of $24,808 and $11,800.71, respectively. The petition in this case seeks a redetermination only of the deficiency for 1991.

The issue for our consideration is whether petitioners had unreported Schedule C income in taxable year 1991.

FINDINGS OF FACT1

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