United States Tax Court October 26, 1987, Docket Nos. 30402-84, 30420-84 (Peoples Loan & Trust Co. v. Commissioner)

lead-opinion

KÓRNER, Judge:

In these consolidated cases, the Commissioner determined that petitioner Peoples Loan & Trust Co., as possessor of certain cash, had a deficiency in Federal income tax of $113,250 for 1983, and that petitioner Leon E. Hendrickson, as possessor of certain cash, had a deficiency in Federal income tax of $1,834,500.25 for 1983.