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HELLER v. COMMISSIONER

Docket No. 6545-77.

40 T.C.M. 1338 (1980)

T.C. Memo. 1980-417

Kenneth Heller and Maria Heller v. Commissioner.

United States Tax Court.

Filed September 22, 1980.

Attorney(s) appearing for the Case

Patrick J. Murphy, 100 Park Ave., New York, N.Y., for the petitioners. Vincent R. Barrella, for the respondent.

Memordandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax and additions to tax under sections 6651(a)(1) and 6653(a), I.R.C. 1954,1 for the calendar year 1973 in the amounts of $33,627, $1,681.35 and $2,561.85, respectively.

The issues for decision are: (1) whether petitioners are entitled to deduct as ordinary and necessary business expense the amount of $36...

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