HARMSTON v. COMMISSIONER

Docket No. 8374-71.

61 T.C. 216 (1973)

GORDON J. HARMSTON AND ALICE C. HARMSTON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 14, 1973.


Attorney(s) appearing for the Case

William P. Irwin and George F. Belyea, for the petitioners.

Joyce E. Britt and James Booher, for the respondent.


The Commissioner determined deficiencies in petitioners' income tax in the amounts of $11,530.44, $23,501, and $16,040 for the calendar years 1967, 1968, and 1969, respectively. Petitioner acquired two orange groves, paying $4,500 per acre in respect of each of them over a period of approximately 4 years each. The principal question is whether portions of such amounts may be allocated to services for "management and care" of the groves performed by the seller and thus treated...

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