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REINKE v. COMMISSIONER

Docket No. 8791-76.

41 T.C.M. 1100 (1981)

T.C. Memo. 1981-120

Theodore S. Reinke and Melanie O. Reinke v. Commissioner.

United States Tax Court.

Filed March 16, 1981.

Attorney(s) appearing for the Case

Vernon E. Robbins, 118 Cedar St., Cambridge, Md., for the petitioners. Eugene J. Wien, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $3,614.80 in the petitioners' Federal income tax for 1974. After concessions by the petitioners, the sole issue for decision is whether payments made by Mr. Reinke to a corporation of which he was a shareholder are deductible by the petitioners as a research and experimental expenditure.

All of the facts have been stipulated, and those facts are so found.

The petitioners...

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