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JULIA R. & ESTELLE L. FOUNDATION v. COMMISSIONER

Docket No. 6263-76.

70 T.C. 1 (1978)

JULIA R. & ESTELLE L. FOUNDATION, INCORPORATED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 5, 1978.

Attorney(s) appearing for the Case

Albert R. Mugel, for the petitioner.

Kenneth Bersani, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $1,119.76 in petitioner's excise tax liability under section 4940(a)1 for the taxable year ending December 31, 1973. The sole issue for decision is the extent to which the expenses of petitioner in the conduct of its operations are deductible in determining "net investment income" under section 4940(c).

All of the facts have been stipulated, and the...

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