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GARRISON v. COMMISSIONER

Docket No. 23172-83.

86 T.C. 764 (1986)

LLOYD McKIM GARRISON AND SARAH GARRISON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 22, 1986.

Attorney(s) appearing for the Case

James B. Lewis, William Hay, and Jose E. Trias, for the petitioners.

Brian Masumoto, for the respondent.

STERRETT, Chief Judge:

By notice of deficiency dated June 16, 1983, respondent determined a deficiency in petitioners' Federal income tax for the taxable year ended December 31, 1980, in the amount of $928. The issues for resolution are (1) whether expenses petitioner incurred as an author in writing a book are subject to the provisions of section 280,1 (2) if section 280 applies to authors, whether petitioner is excluded from its...

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