T.C. Memo. 1997-304
UNITED STATES TAX COURT
WILLIAM T. SHIPES, JR. AND KATHY D. SHIPES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18409-95. Filed July 1, 1997.
William T Shipes, Jr., & Kathy D. Shipes, pro sese.
Monica J. Howland, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge: Respondent determined a deficiency of
$39,393 in petitioners' Federal income tax for taxable year 1991.
We must decide whether section 10331 permits the use of multiple
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
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