HUNTER v. COMMISSIONER

Docket No. 5666-64.

46 T.C. 477 (1966)

ROBERT L. HUNTER AND MAE V. HUNTER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 30, 1966.


Attorney(s) appearing for the Case

Oakley Wade, for the petitioners.

J.C. Linge, for the respondent.


DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income tax for the taxable years 1960, 1961, and 1962 in the amounts of $52.88, $42.82, and $39.98, respectively.

The issues for our consideration are:

(1) Whether petitioners are entitled to deduct as an ordinary and necessary business expense under section 162, I.R.C. 1954,1 that portion of each annual assessment paid by them to Highland Irrigation...

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