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GULLION v. COMMISSIONER

Docket No. 549-81.

43 T.C.M. 694 (1982)

T.C. Memo. 1982-106

Stanley O. Gullion and Edith Gullion v. Commissioner.

United States Tax Court.

Filed March 3, 1982.

Attorney(s) appearing for the Case

William Sidney Smith, 4717 Grand Ave., Des Moines, Ia., for the petitioners. Robert M. Fowler, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency of $5,083 in petitioners' Federal income tax for the year 1977. The only issue for decision is whether, for purposes of section 1348,1 capital was a material income-producing factor in petitioner Stanley O. Gullion's concrete flatwork business.

Findings of Fact

Some of the...

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