WEST v. COMMISSIONER

Docket No. 29826-81.

48 T.C.M. 796 (1984)

T.C. Memo. 1984-421

William N. and Polly A. West v. Commissioner.

United States Tax Court.

Filed August 7, 1984.


Attorney(s) appearing for the Case

Stephen L. Kadish and J. Timothy Bender, 2112 East Ohio Bldg., Cleveland, Ohio, for the petitioners. George T. Bell, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined deficiencies in petitioners' 1874 and 1975 Federal income taxes in the amounts of $59,375.00 and $24,197.00, respectively. After concessions, the issues for decision are: (1) whether petitioners are entitled to deductions under sections 163(a),1 167(a), and 162(a)(1) stemming from a purported sale-leaseback...

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