KANEHL v. COMMISSIONER

Docket No. 5285-87.

57 T.C.M. 854 (1989)

T.C. Memo. 1989-322

Richard V. Kanehl v. Commissioner.

United States Tax Court.

Filed July 5, 1989.


Attorney(s) appearing for the Case

Robert H. Hishon and Dan R. Musick, 200 Galleria Parkway, Atlanta, Ga., for the petitioner. Linda J. Wise, for the respondent.


Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

By statutory notice dated November 24, 1986, respondent determined a deficiency in petitioner's 1980 Federal income tax in the amount of $15,280. Respondent also determined that petitioner was liable for an addition to tax pursuant to section 6653(a)1 in the amount of $764. The sole issue is whether certain consulting fees are taxable to petitioner or to Mary Howard Foods...

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