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LOCKE v. COMMISSIONER

Docket No. 4608-74.

65 T.C. 1004 (1976)

JOHN L. LOCKE AND IRENE F. LOCKE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 23, 1976.

Attorney(s) appearing for the Case

Dwight J. Drake, for the petitioners.

Charles L. Eppright, for the respondent.

QUEALY, Judge:

The respondent determined deficiencies for taxable years 1969 and 1970 in the amounts of $11,996.05 and $72,796.60, respectively.

The questions remaining for decision are (1) whether petitioners may deduct, as an ordinary and necessary business expense under section 1621 or as an ordinary and necessary expense for the production of income under section 212, legal...

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