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EPSTEN v. COMMISSIONER

Docket No. 16989-88.

61 T.C.M. 2814 (1991)

T.C. Memo. 1991-252

Robert M. Epsten and Beatrice A. Epsten v. Commissioner.

United States Tax Court.

Filed June 5, 1991.

Attorney(s) appearing for the Case

Jack D. Farris, Clayton A. Reeves, John L. Ruppert, and Todd A. Fisher, for the petitioners. Michael D. Wilder, for the respondent.

Memorandum Opinion

COHEN, Judge:

Respondent determined a deficiency of $23,265 in petitioners' Federal income taxes for 1984. Respondent also determined additions to tax under sections 6653(a)(1) and (2) and 6661(a) and increased interest under then section 6621(c). The deficiencies resulted from disallowance of deductions attributable to petitioners' investment in Capital Equipment Trust, an entity engaged in computer leasing. After concessions, the issues...

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