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LOHRKE v. COMMISSIONER

Docket No. 5279-65.

48 T.C. 679 (1967)

JAMES L. LOHRKE AND JUNE M. LOHRKE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 10, 1967.

Attorney(s) appearing for the Case

Gordon W. Gerber, for the petitioners.

Edward L. Newberger and Dennis C. DeBerry, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency in the petitioners' income tax in the amount of $24,559.91 for the taxable year 1962. The only issue for decision is whether a payment made by the petitioner to a customer of a corporation in which the petitioner had a substantial interest was an ordinary and necessary expense of a trade or business operated by the petitioner as a proprietorship.

FINDINGS...

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