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O'BRIEN v. COMMISSIONER

Docket No. 8541-81.

79 T.C. 776 (1982)

GORDON T. O'BRIEN AND DERELYSE O'BRIEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 9, 1982.

Attorney(s) appearing for the Case

Kevin O. O'Brien, for the petitioners.

Donald T. Rocen and Byron Calderon, for the respondent.

DAWSON, Judge:

Respondent determined a deficiency of $450 in petitioners' Federal income tax for 1977. The issues to be decided are: (1) Whether the amount expended by petitioners for accounting and data processing services performed by their son constitutes wages for purposes of the new jobs credit under section 44B;1 and (2) whether for purposes of determining the investment tax credit under section 38, the basis of new section...

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