Docket No. 11023-85.

57 T.C.M. 292 (1989)

T.C. Memo. 1989-207

Richard R. Russell and Warena W. Russell v. Commissioner.

United States Tax Court.

Filed May 1, 1989.

Attorney(s) appearing for the Case

Mark Townsend, 333 S. Hope St., Los Angeles, Calif., for the petitioners. Monica Melgarejo, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge.

By statutory notice dated January 30, 1985, respondent determined deficiencies in petitioners' Federal income taxes for taxable years 1977, 1978, and 1979 in the amounts of $10,395, $4,969 and $6,315, respectively.

The sole issue for our consideration is whether petitioners properly claimed deductions for business expenses associated with activities organized by their controlled subchapter S...

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