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THOMPSON v. COMMISSIONER

Docket No. 2335-82.

46 T.C.M. 1109 (1983)

T.C. Memo. 1983-487

William A. Thompson, Jr., and Betty A. Thompson v. Commissioner.

United States Tax Court.

Filed August 16, 1983.

Attorney(s) appearing for the Case

Frederick L. Russell and Robert E. Stroud, Court Square Bldg., P.O. Box 1191, Charlottesville, Va. for the petitioners. William L. Ringuette, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1978 in the amount of $17,445.85. The deficiency results from the disallowance by respondent of a deduction under section 1621 for an alleged business expense in the amount of $48,722.39, representing the aggregate of payments made by William A....

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