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MULHERIN v. COMMISSIONER

Docket No. 14114-79.

42 T.C.M. 834 (1981)

T.C. Memo. 1981-454

Brian C. Mulherin and Marie A. Mulherin v. Commissioner.

United States Tax Court.

Filed August 24, 1981.

Attorney(s) appearing for the Case

Brian C. Mulherin, pro se. Michele D. Palmer, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $560 in petitioners' Federal income taxes for 1976. The issue is whether the petitioner was carrying on a trade or business within the meaning of section 1621 when she incurred certain education expenses.

Findings of Fact

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

Petitioners Brian C. Mulherin...

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