LEMLER v. COMMISSIONER

Docket Nos. 918-77, 935-77.

41 T.C.M. 364 (1980)

T.C. Memo. 1980-507

John F. Lemler and Elizabeth G. Lemler v. Commissioner. Eldene A. Smith and June R. Smith v. Commissioner.

United States Tax Court.

Filed November 17, 1980.


Supplemental Memorandum Opinion

DRENNEN, Judge:

By Opinion filed August 13, 1979, this Court determined that the Bellanca demonstration activity of Elhon Corporation, a subchapter S corporation formed and equally owned by Lemler and Smith, was not an activity engaged in for profit and that its losses from that activity were not deductible by John F. Lemler and Eldene A. Smith. Decision was to be entered under Rule 155.

Respondent timely submitted...

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