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PARKER v. COMMISSIONER

Docket No. 24368-81.

50 T.C.M. 1349 (1985)

T.C. Memo. 1985-545

James J. Parker and Rosemarie Parker v. Commissioner.

United States Tax Court.

Filed October 30, 1985.

Attorney(s) appearing for the Case

Charles W. Johnson, 530 South Fourth St., Las Vegas, Nev. for the petitioners. Ronald D. Dalrymple, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined deficiencies in income tax due from petitioners for the years 1977 and 1978 in the respective amounts of $60,557 and $21,505. The only issue is whether the net profits of petitioners for 1977 and 1978 constitute "personal service income" within the meaning of section 1348.1

Findings of Fact...

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