SILVER v. COMMISSIONER

Docket No. 6038-80.

44 T.C.M. 92 (1982)

T.C. Memo. 1982-326

Charles Silver and Marcia Silver v. Commissioner.

United States Tax Court.

Filed June 9, 1982.


Attorney(s) appearing for the Case

Walter G. Schwartz, 235 Montgomery St., San Francisco, Calif., for the petitioners. Charlotte A. Mitchell, for the respondent.


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in the joint Federal income tax of Charles Silver and Marcia J. Silver (petitioners) in the amount of $14,999 for the year 1976. The issue for decision is whether petitioners paid $30,000 during 1976 to Kachuck Enterprises, Inc., for investment advisory fees.

Findings of Fact

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

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