ESTATE OF HELLIWELL v. COMMISSIONER

Docket No. 6004-76.

77 T.C. 964 (1981)

ESTATE OF PAUL L. E. HELLIWELL, DECEASED, MARY JANE MELROSE AND SECURITY TRUST COMPANY, PERSONAL REPRESENTATIVES, AND MARJORIE M. HELLIWELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 29, 1981.


Attorney(s) appearing for the Case

Calvin Eisenberg, Donald A. Statland, Robert D. Zimelis, Randall G. Dick, and Alan F. Segal, for the petitioners.

James F. Kidd and Janet A. Engel, for the respondent.


SIMPSON, Judge:

The Commissioner determined a deficiency of $46,043.74 in the petitioners' Federal income tax for 1972. The sole issue for decision is whether a limited partner in a "motion picture production service partnership" is entitled to deduct any part of the costs paid in 1972 for the production of motion pictures in that year.

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioners...

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