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FLORIDA FARM BUREAU FEDERATION v. COMMISSIONER

Docket No. 1749-74.

65 T.C. 1118 (1976)

FLORIDA FARM BUREAU FEDERATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 16, 1976.

Attorney(s) appearing for the Case

Ronald D. Fairchild, for the petitioner.

Gerald W. Hartley, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency of $10,550.02 in petitioner's Federal income tax for its fiscal year ended October 31, 1970. The only issue for decision is whether petitioner is entitled under sections 5121 and 514 to deduct certain expenses allocable to the nontaxable portion of the rent received from the lease of rental property.

All the facts are stipulated.

At the time...

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