T.C. Memo. 1996-408
UNITED STATES TAX COURT
JOHN A. MALONE AND BRENDA K. MALONE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5069-94. Filed September 9, 1996.
Jill E. Bliss, for petitioners.
William McCarthy and Keith G. Medleau, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined that petitioners had
deficiencies in Federal income tax of $8,276 for 1989, $21,265
for 1990, and $1,901 for 1991.
Petitioners bought all of the stock of Seattle Pump Company,
Inc. (Seattle Pump). They gave the seller a note secured by
letters of credit. The letters of credit were secured in part by
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