William G. and Vivian Loomis - Page 1
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T.C. Memo. 1997-381
UNITED STATES TAX COURT
WILLIAM G. AND VIVIAN LOOMIS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8748-95. Filed August 20, 1997.
Gary C. Randall and James J. Workland, for petitioners.
John M. Altman and David A. Winsten, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
FAY, Judge: Respondent determined a deficiency in peti-
tioners' Federal income tax for the taxable year 1991 in the
amount of $35,528. After concessions, the sole issue for
decision is whether petitioners must include the fair market
value of grain contracts in their alternative minimum taxable
income (AMTI) for 1991.
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