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WALES v. COMMISSIONER

Docket No. 1103-76.

37 T.C.M. 550 (1978)

T.C. Memo. 1978-125

Harold W. Wales and Dorothy K. Wales v. Commissioner.

United States Tax Court.

Filed March 30, 1978.

Attorney(s) appearing for the Case

Leslie A. Plattner, 1830 First National Bank Plaza, 100 W. Washington St., Phoenix, Ariz., for the petitioners. Milton J. Carter, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income tax of $1,150.00 for 1972 and $1,121.00 for 1973. The issue for decision is whether certain payments in 1972 and in 1973 by the petitioner Harold W. Wales to his mother are deductible as interest on indebtedness within the meaning of section 163(a) of the Internal Revenue Code of 1954.1

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