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ROBERTSON v. COMMISSIONER

Docket No. 2873-87.

59 T.C.M. 781 (1990)

T.C. Memo. 1990-275

F.D. and Bobbie J. Robertson v. Commissioner.

United States Tax Court.

Filed May 31, 1990.

Attorney(s) appearing for the Case

Joseph L. Anthony, 213 S. Jefferson St., Roanoke, Va., for the petitioners. Scott Anderson and Richard Stein, for the respondent.

Memorandum Opinion

PETERSON, Chief Special Trial Judge:

Respondent determined a deficiency of $1,433.37 in petitioners' Federal income tax for 1982.

At issue is whether petitioner F.D. Robertson, who owned interests in two real estate partnerships, is entitled to a deduction under section 404(a)(3)1 for a contribution made in 1982 by CSW Associates to its qualified profit-sharing plan where the partnership had no current...

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