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HERMAN v. COMMISSIONER

Docket No. 24369-81.

50 T.C.M. 650 (1985)

T.C. Memo. 1985-396

Max B. Herman and Pearl Herman v. Commissioner.

United States Tax Court.

Filed August 7, 1985.

Attorney(s) appearing for the Case

Charles William Johnson, 530 S. 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 petitioners' income taxes for 1976 and 1977 in the respective amounts of $7,420 and $10,210. The only issue is whether under section 13481 capital was a material income-producing factor in the motel business operated by petitioners.

Findings of Fact

Some of the facts...

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