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NAGY v. COMMISSIONER

Docket No. 3633-76.

37 T.C.M. 1326 (1978)

T.C. Memo. 1978-318

Ernest J. Nagy and Jane H. Nagy v. Commissioner.

United States Tax Court.

Filed August 15, 1978.

Attorney(s) appearing for the Case

John L. Carey and Richard B. Urda, Jr., First Bank Bldg., South Bend, Ind., for the petitioners. Elsie Hall, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency of $66,906 in petitioners' 1972 income tax. After concessions, the sole issue is whether certain payments were capital expenditures under section 2631 or ordinary and necessary business expenses under sections 162 and 212.

Findings of Fact

Some of the facts were stipulated and are found accordingly.

Ernest (hereinafter...

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