NOVIKOFF v. COMMISSIONER

Docket No. 13341-78.

40 T.C.M. 1039 (1980)

T.C. Memo. 1980-330

Melvin Novikoff and Susan Novikoff v. Commissioner.

United States Tax Court.

Filed August 25, 1980.


Attorney(s) appearing for the Case

Jerry J. Goldstein, 555 California St., San Francisco, Calif., for the petitioners. Milton B. Blouke, for the respondent.


Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a $4,051 deficiency in petitioners' 1976 income tax. The sole issue for decision is whether capital was a material income-producing factor in petitioner's movie theater business.

Findings of Fact

Some of the facts have been stipulated by the parties and are found accordingly.

Melvin ("petitioner") and Susan Novikoff1 resided in...

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