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ROUSKU v. COMMISSIONER

Docket No. 2946-70.

56 T.C. 548 (1971)

GEORGE ROUSKU AND ESTHER ROUSKU, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 21, 1971.

Attorney(s) appearing for the Case

Wilfred L. Burke, for the petitioners.

Patrick R. McKenzie, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' income tax for 1967 in the amount of $734.73. The only issue presented for decision is whether, within the meaning of section 911,1 capital was a material income-producing factor in an automobile body repair business which petitioner George Rousku conducted in Canada.

FINDINGS OF FACT

George Rousku (hereinafter referred to as petitioner) and...

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