T.C. Memo. 2001-100
UNITED STATES TAX COURT
DANIEL E. AND KAREN A. HARKINS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15623-99. Filed April 26, 2001.
Tim A. Tarter, for petitioners.
John W. Duncan and Ann M. Welhaf, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$111,311 in petitioners' 1996 Federal income tax. After various
concessions,1 the issues presented to us are (1) whether
1 We summarily describe certain concessions not discussed
in the Findings of Fact. Petitioners stipulate that they must
include in income $8,658 for fringe benefits received from
Harkins Amusement Enterprises, Inc. (in the form of paid medical
insurance premiums), while respondent allows a partially
offsetting health insurance deduction of $2,597 for self-employed
(continued...)
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