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CONWAY v. COMMISSIONER

Docket No. 584-80.

44 T.C.M. 269 (1982)

T.C. Memo. 1982-358

Hobart M. Conway, Jr. and Rebecca K. Conway v. Commissioner.

United States Tax Court.

Filed June 24, 1982.

Attorney(s) appearing for the Case

William E. Frantz and Clarence H. Glover, Jr., 3390 Peachtree Road N.E., Atlanta, Ga., for the petitioners. Julian A. Fortuna, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $2,025 for 1973 and $3,719 for 1976. The issues for decision are: (1) Whether section 46(e)(3) of the Internal Revenue Code of 1954,1 relating to noncorporate lessors, denies the petitioners an investment tax credit for an aircraft which they purchased and allowed their corporation to use...

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