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JENKINS v. COMMISSIONER

Docket No. 3354-79.

47 T.C.M. 238 (1983)

T.C. Memo. 1983-667

Harold L. and Temple M. Jenkins v. Commissioner.

United States Tax Court.

Filed November 3, 1983.

Attorney(s) appearing for the Case

Theodore L. Jones, William G. Whatley and Alva C. Smith, Jr., 3081 Teddy Dr., Baton Rouge, La. for the petitioners. Charles W. Kite, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined deficiencies of $67,141 and $14,226 in petitioners' Federal income taxes for their 1973 and 1974 taxable years, respectively. After concessions by petitioners and respondent,1 the sole issue for our decision is whether certain payments made by petitioner-husband to investors in a defunct restaurant business known as "Twitty Burger, Inc.," are deductible...

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