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KRAMER v. COMMISSIONER

Docket No. 3911-79.

80 T.C. 768 (1983)

JOHN A. KRAMER AND GLORIA L. KRAMER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 25, 1983.

Attorney(s) appearing for the Case

Mark Townsend, for the petitioners.

Karen J. Simonson, for the respondent.

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' Federal income taxes for 1975 and 1976 in the amounts of $15,752 and $23,088, respectively. The sole issue for decision is whether certain amounts received by petitioner John A. Kramer during those years constituted "earned income" for purposes of the maximum tax on earned income and the computation of the maximum deductible contribution to a self-employment pension (Keogh) plan.

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