STRANGE v. COMMISSIONER

Docket No. 8602-98.

114 T.C. 206 (2000)

CHARLES E. AND SHERRIE R. STRANGE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 29, 2000.


Attorney(s) appearing for the Case

L. Robert LeGoy, Jr., and Kurt O. Hunsberger, for petitioners.

Paul L. Dixon, for respondent.


OPINION

PARR, Judge:

Respondent determined deficiencies of $3,955, $5,379, and $3,983 in petitioners' Federal income taxes for the taxable years 1993, 1994, and 1995, respectively. The sole issue for decision is whether State nonresident income taxes paid on net royalty income are deductible for purposes of determining adjusted gross income. We hold they are not.

Background

This case was submitted fully stipulated under Rule...

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