CITRUS ORTHOPEDIC MEDICAL GROUP, INC. v. COMMISSIONER

Docket No. 8771-77.

72 T.C. 461 (1979)

CITRUS ORTHOPEDIC MEDICAL GROUP, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 11, 1979.


Attorney(s) appearing for the Case

H. Bradley Jones and Richard Saavedra, for the petitioner.

Karl D. Zufelt, for the respondent.


OPINION

FEATHERSTON, Judge:

Respondent determined deficiencies in the amounts of $3,520 and $10,423 in petitioner's Federal income tax for the taxable years ended March 31, 1974, and March 31, 1975, respectively. The issues for decision are whether payments made by petitioner during those years to an educational benefit trust established for the children of certain of petitioner's employees are deductible, and if so, in what taxable years.

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