HARRINGTON v. COMMISSIONER

Docket No. 6746-77.

37 T.C.M. 1847 (1978)

T.C. Memo. 1978-458

Clark J. Harrington v. Commissioner.

United States Tax Court.

Filed November 15, 1978.


Attorney(s) appearing for the Case

Lester J. Schaffer, Four Penn Center Plaza, Philadelphia, Pa., for the petitioner. William L. Autman, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $5,752.22 and an addition to tax of $3,357.25 under section 6653(b), Internal Revenue Code of 1954, for the taxable year 1972. Petitioner not having disputed any other adjustments in the notice of deficiency, the sole issues for decision are (1) whether petitioner received $20,000 for services in connection with the obtaining of a loan from the Small Business...

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