MARTIN v. COMMISSIONER

Docket No. 12489-79.

43 T.C.M. 1216 (1982)

T.C. Memo. 1982-226

Philip E. Martin and Eileen F. Martin v. Commissioner.

United States Tax Court.

Filed April 28, 1982.


Attorney(s) appearing for the Case

William A. Brandwein, 42 East Gay Street, Columbus, Ohio, for the petitioners. Eugene P. Bogner, for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in petitioners' 1972 Federal income tax in the amount of $13,659.01. The deficiency is attributable to certain adjustments to petitioner Philip Martin's distributive share of the losses of two real estate partnerships in which he was a partner during 1972. Two issues are presented for decision:

(1) Whether the entire amount of a $64,500 payment to partner Jack...

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