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BARNES v. COMMISSIONER

Docket No. 108-86.

54 T.C.M. 972 (1987)

T.C. Memo. 1987-544

George E. Barnes and Florence H. Barnes v. Commissioner.

United States Tax Court.

Filed October 26, 1987.

Attorney(s) appearing for the Case

Loren E. Juhl, for the petitioners. Janine M. Poronsky, for the respondent.

Memorandum Opinion

COHEN, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

Year                               Deficiency

1976 ...........................   $6,375.70
1977 ...........................    5,258.47
1978 ...........................      934.71

The sole issue for decision is whether capital was a material income-producing factor in petitioner George E. Barnes...

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