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McGOWAN v. COMMISSIONER

Docket No. 10001-79.

43 T.C.M. 495 (1982)

T.C. Memo. 1982-65

Richard B. McGowan and Joanne McGowan v. Commissioner.

United States Tax Court.

Filed February 11, 1982.

Attorney(s) appearing for the Case

Thomas I. Hara, 400 S. Co. Rd. 18, Minneapolis, Minn., for the petitioners. Sue A. Nelson, for the respondent.

Memorandum Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income tax in the amount of $17,987 for the taxable year 1975 and $22,663 for the taxable year 1976. Due to concessions made by the petitioners, the only issue for decision is whether petitioner Richard B. McGowan was engaged during the years 1975 and 1976 in a business in which capital constituted a material income-producing factor so that a maximum of...

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