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HAMM v. COMMISSIONER

Docket No. 9049-78.

40 T.C.M. 284 (1980)

T.C. Memo. 1980-154

Kenneth G. and Bettye W. Hamm v. Commissioner.

United States Tax Court.

Filed May 5, 1980.

Attorney(s) appearing for the Case

Ford T. Bussart, Rock Springs Natl. Bank Bldg., Rock Springs, Wyo., for the petitioners. Benjamin A. De Luna, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies of $9,382.75, $5,140.50, and $788.73 in petitioners' Federal income taxes for 1973, 1974, and 1975, respectively. The only issue for decision is whether income earned by petitioner Kenneth G. Hamm is reportable as partnership income or as personal income.

All of the facts have been stipulated.

Petitioners Kenneth G. Hamm (petitioner) and Bettye W. Hamm, husband and...

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