T.C. Memo. 1997-529
UNITED STATES TAX COURT
BOBBY E. SYPHRETT AND JANICE D. SYPHRETT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16340-95. Filed November 24, 1997.
David C. Allie and Walter B. Thurmond, for petitioners.
Richard T. Cummings, for respondent.
MEMORANDUM OPINION
LARO, Judge: The parties submitted this case to the Court
without trial. See Rule 122. Petitioners petitioned the Court
to redetermine respondent's determination of a $126,510
deficiency in their 1989 Federal income tax. Following certain
concessions by petitioners, we must decide whether their 1989
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