T.C. Memo. 2005-149
UNITED STATES TAX COURT
THOMAS B. HAWKINS AND LEANNA L. HAWKINS, DECEASED,
THOMAS B. HAWKINS, SUCCESSOR IN INTEREST, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18450-02. Filed June 23, 2005.
Douglas A. MacDonald, for petitioners.
Kathryn K. Vetter, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$194,7431 in petitioners’ 1998 Federal income tax. After the
stipulation to be bound,2 the issues for decision are whether
1 All amounts are rounded to the nearest dollar.
2 Petitioners argued on brief that they could exclude from
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