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FRANCK v. COMMISSIONER

Docket No. 1972-79.

41 T.C.M. 1475 (1981)

T.C. Memo. 1981-235

Richard L. Franck and Dolores L. Franck v. Commissioner.

United States Tax Court.

Filed May 12, 1981.

Attorney(s) appearing for the Case

Mark Townsend, 333 South Hope St., Los Angeles, Calif. for the petitioners. J. Robert Cuatto, for the respondent.

Memorandum Opinion

GOFFE, Judge:

The Commissioner determined a deficiency of $2,242 in the Federal income tax of petitioners for the taxable year 1975. The issues are:

(1) whether section 1.44-2 of the Income Tax Regulations is valid and enforceable, and

(2) whether the construction of petitioners' residence commenced before March 26, 1975, for purposes of section 44(e)(1) (A), Internal Revenue Code of 1954.1...

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