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LOEFFLER v. COMMISSIONER

Docket No. 12564-81.

46 T.C.M. 1153 (1983)

T.C. Memo. 1983-503

Alan B. and Louise M. Loeffler v. Commissioner.

United States Tax Court.

Filed August 22, 1983.

Attorney(s) appearing for the Case

Michael E. Zaden, for the petitioners. Karen Nicholson Sommers, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax in the amounts of $17,797 and $23,678 for the years 1977 and 1978, respectively, and additions to tax under section 6653(a)1 in the amounts of $890 and $1,184, respectively, for these years.

The issues for decision are (1) whether petitioners are taxable on income resulting from services of Alan B. Loeffler...

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