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FULTON v. COMMISSIONER

Docket No. 2064-80.

45 T.C.M. 502 (1983)

T.C. Memo. 1983-17

Virgil David Fulton and Martha Patricia Fulton v. Commissioner.

United States Tax Court.

Filed January 11, 1983.

Attorney(s) appearing for the Case

Martha Patricia Fulton, pro se, Fort Worth, Tex. James J. Everett, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined a deficiency in petitioners' 1976 Federal income taxes in the amount of $1,199. The sole issue before us is whether the fair market value of the education furnished to petitioners' three children during 1976 is includable in petitioners' gross income under section 61.1 and taxable to them in such year.

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