ROSENFELD v. COMMISSIONER

Docket No. 789-79.

43 T.C.M. 1353 (1982)

T.C. Memo. 1982-263

George B. Rosenfeld and Harriet Rosenfeld v. Commissioner.

United States Tax Court.

Filed May 12, 1982.


Attorney(s) appearing for the Case

John P. Dee, 70 Niagara St., Buffalo, N.Y., for the petitioners. Jerome F. Warner, for the respondent.


Memorandum Findings of Fact and Opinion

SIMPSON, Judge:*

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $5,770.50 for 1974 and $4,916.65 for 1975. After concessions by the petitioners, the sole issue for decision is whether the amounts paid as rent by Dr. Rosenfeld during 1974 and 1975 to trusts created by him for the benefit of his children constituted ordinary and necessary business expenses...

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