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FEGAN v. COMMISSIONER

Docket No. 5253-77.

71 T.C. 791 (1979)

THOMAS B. FEGAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 14, 1979.

Attorney(s) appearing for the Case

Murray F. Hardesty, for the petitioner.

John Wendell Paul, for the respondent.

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable years 1970, 1971, 1972, and 1973 in the amounts of $4,643, $29,247, $32,852, and $4,284, respectively.

The issues for decision are:

(1) Whether under section 482, I.R.C. 1954,1 respondent properly allocated to petitioner for each of the years 1971, 1972, and 1973 additional rental income from a motel facility owned by petitioner...

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