MANISCALCO v. C. I. R.

No. 78-1591.

632 F.2d 6 (1980)

Joseph MANISCALCO, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided October 8, 1980.


Attorney(s) appearing for the Case

John M. Rickel, Rickel, Urso, Wokas & Earle, Detroit, Mich., for petitioner-appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Tax Division, U. S. Dept. of Justice, Washington, D. C., Richard Farber, David Allen, Anthony Ilardi, Jr., Stuart E. Seigel, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before BOYCE F. MARTIN and JONES, Circuit Judges, DUNCAN, District Judge.


PER CURIAM.

This appeal involves review of a decision of the United States Tax Court, 37 T.C.M. 1174 (1978), denying taxpayer a deduction for certain claimed expenses and donations. Review jurisdiction of the decision is granted under 26 U.S.C. § 7482.

During the tax year under review, 1974, taxpayer was a full-time professional artist. On his federal tax return for that year he claimed as an advertising and public relations expense his valuation of three...

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