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EPP v. COMMISSIONER

Docket No. 12740-79.

78 T.C. 801 (1982)

SUSAN H. EPP, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 12, 1982.

Attorney(s) appearing for the Case

Donald B. Brown and Barbara J. Rose, for the petitioner.

Peter D. Bakutes and Catherine L. Wong, for the respondent.

SIMPSON, Judge:*

The Commissioner determined a deficiency of $848 in the petitioner's Federal income tax for 1976 and an addition to tax of $42.40 under section 6653(a) of the Internal Revenue Code of 1954.1 By agreement of the parties, the sole issue for decision at this time is whether the petitioner is entitled to deduct under section 212 the expenses of establishing à family estate trust.

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