WORLEY v. COMMISSIONER

Docket No. 2888-78.

39 T.C.M. 1090 (1980)

T.C. Memo. 1980-51

Carl M. Worley and Constance M. Worley v. Commissioner.

United States Tax Court.

Filed February 27, 1980.


Attorney(s) appearing for the Case

John D. Houston II, James M. Houston, and Thomas E. Lippard, 600 Grant St., Pittsburgh, Pa. for the petitioners. Carmen J. SantaMaria, for the respondent.


Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies of $18,271.19 and $13,386.21, in petitioners' Federal income tax for 1972 and 1973, respectively.

Due to concessions by the parties, the only issues remaining for decision are:

1. Whether expenses petitioners incurred in operating, maintaining, and housing their airplane are deductible in full under section 162,1 or...

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