United States Tax Court January 4, 2002, No. 1287-00; No. 1288-00; No. 1289-00; No. 1290-00; No. 1291-00; No. 1292-00; No. 1293-00; No. 1618-00 (Allen v. Comm'r)

lead-opinion

OPINION

Laro, Judge:

This case was submitted to the Court without trial. See Rule 122.2 Petitioners petitioned the Court to redetermine respondent’s determination of the following deficiencies in their Federal income taxes for 1994 and 1995:

Petitioner 1994 1995

Charles C. Allen III and Barbara N. Allen $21,321 $12,107

Charles C. Allen, Jr. 21,324 12,015

John R.