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PHILLIPS v. COMMISSIONER

Docket No. 4745-94.

106 T.C. 176 (1996)

MICHAEL W. AND CHARLOTTE S. PHILLIPS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 7, 1996.

Attorney(s) appearing for the Case

Joseph B. Schimmel and Alan R. Chase, for petitioners.

Ellen T. Fribourg and James P. Dawson, for respondent.

OPINION

LARO, Judge:

Michael W. and Charlotte S. Phillips petitioned the Court for redetermination of deficiencies determined by respondent for their 1984 and 1986 taxable years in the amounts of $25,471 and $69,714, respectively. After petitioners conceded the deficiency for 1984, the sole issue for decision is whether petitioners avoided recapture of an investment credit claimed for property of a partnership subject to sections 6221 through 6231...

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