DANIEL v. COMMISSIONER

Docket No. 1580-75.

37 T.C.M. 1180 (1978)

T.C. Memo. 1978-277

Clarence R. Daniel and Nancy H. Daniel v. Commissioner.

United States Tax Court.

Filed July 24, 1978.


Attorney(s) appearing for the Case

Thomas J. Stevens and F. Timothy Nicholls, 400 Wachovia Bank Bldg., Durham, N.C., for the petitioners. Mathew E. Bates, for the respondent.


Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1971 and 1972 in the amounts of $493.32 and $1,560.38, respectively.

After concessions of the parties, the only issue which remains for our decision is whether certain payments made by petitioners represent the payment of ordinary and necessary expenses of carrying on a trade or business, or expenses incurred...

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