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HUTCHINSON v. COMMISSIONER

Docket No. 2661-75.

41 T.C.M. 531 (1980)

T.C. Memo. 1980-551

J. Albert Hutchinson and Augusta P. Hutchinson v. Commissioner.

United States Tax Court.

Filed December 15, 1980.

Attorney(s) appearing for the Case

J. Albert Hutchinson, pro se., 55 New Montgomery St., San Francisco, Calif. Milton B. Blouke, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' 1970 and 1971 Federal income tax[es] of $4,317.96 and $1,520.18, respectively. Due to concessions, the remaining issues for decision are:

1. Whether petitioners are entitled to a $10,000 intangible drilling expense deduction in 1970; if so, whether petitioners must include in income $10,000 received in 1971 from the rescission of their participation...

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