JOHNSTON v. COMMISSIONER

Docket No. 428-76.

37 T.C.M. 544 (1978)

T.C. Memo. 1978-121

James R. Johnston v. Commissioner.

United States Tax Court.

Filed March 27, 1978.


Attorney(s) appearing for the Case

Pipp M. Boyls, 2204 Oakridge Ln., Colorado Springs, Colo., for the petitioner. Fredrick B. Strothman, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency in petitioner's income tax for 1973 of $485.00, plus an addition to tax under section 6653(a)1 of $24.25.

The issues for decision are whether petitioner may deduct under section 162 or 212, an expenditure of $1,750 incurred in purchasing a trust instrument and whether any part of the underpayment (if such underpayment exists) of tax...

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