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SPALDING v. COMMISSIONER

Docket No. 8064-73.

66 T.C. 1017 (1976)

DOLPH AND THELMA S. SPALDING, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 9, 1976.

Attorney(s) appearing for the Case

Robert E. Kovacevich and Richard P. Algeo, for the petitioners.

Charles L. Eppright, for the respondent.

HALL, Judge:

Respondent determined a deficiency of $691.78 in petitioners' 1971 Federal income tax.

The sole issue is whether a fence erected by petitioners in 1971 to enclose a portion of their auto wrecking business qualifies as "section 381 property" for purposes of the investment credit.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found...

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