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LEBERT v. COMMISSIONER

Docket No. 14606-83.

48 T.C.M. 1502 (1984)

T.C. Memo. 1984-578

Elder W. Lebert and Mina C. Lebert v. Commissioner.

United States Tax Court.

Filed October 31, 1984.

Attorney(s) appearing for the Case

William B. Schendel (specially recognized), for the petitioners. Milton J. Carter, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $2,521 in petitioners' 1980 Federal income tax. After concessions by petitioners, the sole issue is whether certain litigation expenses were incurred by petitioner in the carrying on of a trade or business within the meaning of section 162(a)1 or in the production or collection of income within the meaning of section 212(1).

Findings...

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