T.C. Memo. 1997-122
UNITED STATES TAX COURT
STEPHEN P. AND JUTTA A. MARANTO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19822-95. Filed March 10, 1997.
Stephen P. and Jutta Maranto, pro sese.
James J. Posedel, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined a deficiency of $10,810
in petitioners' 1991 Federal income tax. Respondent further
determined an addition to tax pursuant to section 66541 in the
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
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