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BUSSICULO v. COMMISSIONER

Docket No. 15810-82.

54 T.C.M. 549 (1987)

T. C. Memo. 1987-467

Rosemary Bussiculo v. Commissioner.

United States Tax Court.

Filed September 16, 1987.

Attorney(s) appearing for the Case

Thomas B. Rutter and Robin E. Williams, 872 Public Ledger Bldg., Philadelphia, Pa., for the petitioner. Michael R. Rizzuto and Edward G. Martoglio, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for the calendar years 1978 and 1979 in the amounts of $17,724 and $43,228, respectively. After concessions, the sole issue for decision is whether the amounts paid to petitioner as salaries and bonuses by Epicor, Inc., a subchapter S corporation, constituted personal service income within the meaning of section 1348

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