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WARD v. COMMISSIONER

Docket No. 10296-81.

48 T.C.M. 1479 (1984)

T.C. Memo. 1984-570

Jimmie J. Ward and Bonnie M. Ward v. Commissioner.

United States Tax Court.

Filed October 24, 1984.

Attorney(s) appearing for the Case

John Patrick Kelly, for the petitioners. John O. Kent, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined a $7,680 deficiency in petitioners' 1977 income tax. At issue is the deductibility of $22,500 as "royalties" on Schedule C of their 1977 return. The case was presented on the basis of a stipulation of facts and the Commissioner's unopposed Request for Admissions.

Petitioners, husband and wife, resided in Las Vegas, Nevada, when they filed...

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