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ROLLINS v. COMMISSIONER

Docket No. 6480-77.

38 T.C.M. 1274 (1979)

T.C. Memo. 1979-331

O. Wayne Rollins and Grace W. Rollins v. Commissioner.

United States Tax Court.

Filed August 22, 1979.

Attorney(s) appearing for the Case

Michael C. Russ, L. Joseph Loveland, and William F. Nelson, 2500 Trust Co. Tower, Atlanta, Ga. 30303, for the petitioners. Albert L. Sandlin, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $95,035 in petitioners' 1972 Federal income tax.

The sole issue for decision is whether a $160,000 payment made to a trust, which was established by petitioner O. Wayne Rollins and his brother for the purpose of liquidating debts of businesses owned wholly or in part by their uncle, is deductible in full under sections 162(a)1

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