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ESTATE OF SUSSMAN v. COMMISSIONER

Docket No. 4547-76.

37 T.C.M. 1430 (1978)

T.C. Memo. 1978-344

Estate of Henry Sussman, Deceased, Public Administrator of New York County v. Commissioner.

United States Tax Court.

Filed August 30, 1978.

Attorney(s) appearing for the Case

Louis A. Gruhin, for the petitioner. David A. Schmudde, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $461.12 in petitioner's 1974 Federal income tax.1 The sole issue for decision is whether petitioner was in the trade or business of being an accountant in 1974.

All of the facts have been stipulated and are found accordingly. The stipulation of facts and the exhibits attached thereto are incorporated herein by reference.

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