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BRUNO v. COMMISSIONER

Docket No. 7284-76.

71 T.C. 191 (1978)

DOROTHY BRUNO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 20, 1978.

Attorney(s) appearing for the Case

Charles C. Shafer, Jr., for the petitioner.

John Wendell Paul, for the respondent.

FORRESTER, Judge:

Respondent has determined deficiencies in petitioner's Federal income tax for the taxable years 1973 and 1974 in the amounts of $6,890.70, and $10,488.98, respectively. Concessions having been made, the only issue remaining for our decision is whether, for purposes of section 1348,1 petitioner employs capital as a material income-producing factor in the business of writing bail bonds.

FINDINGS OF FACT...

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