PRIMUTH v. COMMISSIONER

Docket No. 3954-68.

54 T.C. 374 (1970)

DAVID J. PRIMUTH AND CAROL J. PRIMUTH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 2, 1970.


Attorney(s) appearing for the Case

William F. Kolbe, for the petitioners.

Alan B. Shidler, for the respondent.


STERRETT, Judge:

Respondent determined a deficiency of $754.10 in the petitioners' Federal income tax for the taxable year 1966. The only issue for decision is whether respondent was correct in its determination that $3,016.43 expended by petitioners to secure new employment is not deductible under section 162 or 212, I.R.C. 1954.1

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation...

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