Docket No. 4586-76.

42 T.C.M. 1533 (1981)

T.C. Memo. 1981-623

Jeffrey Edmondson, a/k/a Jeff Edmondson v. Commissioner.

United States Tax Court.

Filed October 26, 1981.

Attorney(s) appearing for the Case

Saul A. Bernick and Neal Shapiro, 1024 Soo Line Bldg., Minneapolis, Minn., for the petitioner. James C. Lanning, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioner's Federal income tax liability for the taxable year 1974 in the amount of $17,303.45 together with an addition to tax under section 6651 (a), Internal Revenue Code of 1954,1 in the amount of $289.87. There are two issues for decision:

(1) whether respondent has properly disallowed portions of petitioner's cost...

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