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JONES v. COMMISSIONER

Docket No. 12287-79.

44 T.C.M. 1456 (1982)

T.C. Memo. 1982-612

Casey W. Jones and Margie K. Jones v. Commissioner.

United States Tax Court.

Filed October 20, 1982.

Attorney(s) appearing for the Case

Martin A. Welp, 1027 Opelousas Ave., New Orleans, La., for the petitioners. Robert J. Burbank, for the respondent.

Memorandum Opinion

HAMBLEN, Judge:*

Respondent determined a deficiency of $1,518 in petitioners' 1976 Federal income tax. The sole issue for decision is whether capital was a material income-producing factor in petitioners' retail grocery business within the meaning of section 1348.1

All of the facts have been stipulated and are found accordingly.

Petitioners, Casey W. Jones and Margie...

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