WOLFE v. COMMISSIONER

Docket No. 15348-80.

48 T.C.M. 919 (1984)

T.C. Memo. 1984-446

Stanley J. Wolfe and Helen W. Wolfe v. Commissioner.

United States Tax Court.

Filed August 21, 1984.


Attorney(s) appearing for the Case

Peter L. Lawrence, for the petitioner. Joseph Long, for the respondent.


Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency in the amount of $2,039.00 in petitioners' 1977 individual Federal income taxes. The sole issue for decision is whether petitioners are entitled to a deduction under section 162(a)1 for rental payments on land gifted to an irrevocable ten year trust.

Findings of Fact

Some of the facts have been stipulated and are found...

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