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RUHLMAN v. COMMISSIONER

Docket No. 9198-73.

35 T.C.M. 349 (1976)

T.C. Memo. 1976-81

Joseph K. Ruhlman and Jean M. Ruhlman v. Commissioner.

United States Tax Court.

Filed March 16, 1976.

Attorney(s) appearing for the Case

Leonard J. Prekel, 2225 City National Bank Bldg., Detroit, Mich., for the petitioners. Peter M. Ritteman, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent has determined deficiencies in petitioners' Federal income tax as follows:

    Taxable
     Year                 Deficiency

    1969 ..............   $5,562.98
    1970 ..............    7,064.90
    1971 ..............    4,939.55

The sole issue for decision is whether the payments made by petitioners in 1969, 1970 and 1971 represent part of the purchase price...

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