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ZAHLER v. COMMISSIONER

Docket No. 2638-78.

41 T.C.M. 1074 (1981)

T.C. Memo. 1981-112

William P. Zahler and Rowena L. Zahler v. Commissioner.

United States Tax Court.

Filed March 10, 1981.

Attorney(s) appearing for the Case

Loyal E. Luikart, Jr., 18975 Villaview Dr., Cleveland, Ohio, for the petitioners. Barbara B. McCaskill, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1972 and 1973 in the amounts of $11,627.99 and $1,124.53, respectively. After concession by petitioners of one issue, the issue for decision is whether commissions received by petitioner William P. Zahler from a partnership with respect to which capital was a material income-producing factor and in which he was...

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