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HARRIS v. COMMISSIONER

Docket No. 7878-78.

41 T.C.M. 815 (1981)

T.C. Memo. 1981-46

Oliver G. Harris and Wilma L. Harris v. Commissioner.

United States Tax Court.

Filed February 4, 1981.

Attorney(s) appearing for the Case

Paul T. Wright, for the petitioners. Deborah A. Butler, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

For the taxable years 1974 and 1975, respondent determined deficiencies in petitioners' income tax in the respective amounts of $1,503.51 and $2,973.84, and additions to tax under section 6653(a)1 in the respective amounts of $75.18 and $148.69. The issues for decision are: (1) whether petitioners' conveyances of their lifetime services to a trust constitute assignments of...

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