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MaDAN v. COMMISSIONER

Docket No. 5072-80.

51 T.C.M. 241 (1986)

T.C. Memo. 1986-7

Gerard H. MaDan and Dorothy M. MaDan v. Commissioner.

United States Tax Court.

Filed January 7, 1986.

Attorney(s) appearing for the Case

James E. Merritt, for the petitioners. Frank D. Armstrong, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax of $5,183.05 for the taxable year 1976. The only issue is whether petitioners converted their former residence into property held for the production of income for computing a loss under section 1651 and depreciation under section 167 and, if so, the amount of the loss and the depreciation they are entitled...

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