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PATTON v. COMMISSIONER

Docket No. 8757-77.

71 T.C. 389 (1978)

JAMES W. PATTON AND HELEN PATTON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 20, 1978.

Attorney(s) appearing for the Case

Stanley R. Kirk, for the petitioners.

Joseph C. Hollywood and William D. Brackett, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined a deficiency of $680.95 in petitioners' Federal income tax for 1974. The issue is whether an amount paid as a penalty under section 6672, I.R.C. 1954,1 may be deducted as an employee business expense under section 162.

This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and attached exhibits are incorporated...

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