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WOESNER ABSTRACT & TITLE CO. v. COMMISSIONER

Docket No. 7738-80.

47 T.C.M. 722 (1983)

T.C. Memo. 1983-764

Woesner Abstract & Title Co., by Mitchell M. Woesner, President v. Commissioner.

United States Tax Court.

Filed December 20, 1983.

Attorney(s) appearing for the Case

Mitchell M. Woesner (President), for the petitioner. James M. Klein, Sheldon M. Kay, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency of $2,152 in the income tax due from petitioner for 1976. The sole issue for our decision is whether petitioner is entitled to deduct, under section 162(a)(1)1 as compensation for services the amount paid to Will Woesner during 1976 in excess of the amount allowed by respondent.

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