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ESTATE OF DONNELLY v. COMMISSIONER

Docket No. 578-80.

44 T.C.M. 1196 (1982)

T.C. Memo. 1982-551

Estate of Francis M. Donnelly, Sr., Deceased, Marion Y. Donnelly, Executrix, and Marion Y. Donnelly v. Commissioner.

United States Tax Court.

Filed September 23, 1982.

Attorney(s) appearing for the Case

K.G. Seitz, 4321 Hamilton Ave., Cincinnati, Ohio, for the petitioners. Kenneth P. Dale, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1976 of $5,522. The issue for decision is whether petitioners have substantiated business travel expense deductions in the amount of $25,185 in that year under the strictures of section 274(d).1

Findings of Fact

Some of the facts have been stipulated. The stipulation...

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