United States Tax Court December 27, 1990, Docket No. 23782-88 (Berry v. Commissioner)

JAMES C. and CARLYDIA BERRY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Berry v. Commissioner Docket No. 23782-88 United States Tax Court T.C. Memo 1990-646; 1990 Tax Ct. Memo LEXIS 738; 60 T.C.M. (CCH) 1499; T.C.M. (RIA) 90646; December 27, 1990, Filed *738 Decision will be entered for the respondent. Petitioners were taxpayers in the refund case of Berry v.