Robert Schelble and Susan Schelble - Page 1

                                    T.C. Memo. 1996-269                                      


                                 UNITED STATES TAX COURT                                     


                   ROBERT SCHELBLE AND SUSAN SCHELBLE, Petitioners v.                        
                      COMMISSIONER OF INTERNAL REVENUE, Respondent                           


                Docket No. 12747-93.                  Filed June 12, 1996.                   

                Richard Clark, for petitioners.                                              
                James Gehres, for respondent.                                                

                                    MEMORANDUM OPINION                                       
                FAY, Judge:  By statutory notice of deficiency dated                         
          March 17, 1993, respondent determined deficiencies in peti-                        
          tioner's1 income tax for the taxable years 1989, 1990 and 1991,                    
          in the amounts of $4,334, $4,489 and $1,362, respectively.  The                    
          sole issue for decision is whether termination payments provided                   
          by petitioner's employer and received by petitioner after                          
          retirement from service as an independent insurance agent are                      


          1All references to petitioner are to Robert Schelble.                              




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