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LEUBERT v. COMMISSIONER

Docket No. 9742-76.

46 T.C.M. 945 (1983)

T.C. Memo. 1983-457

Alfred O.P. Leubert and Celestine C. Leubert v. Commissioner.

United States Tax Court.

Filed August 4, 1983.

Attorney(s) appearing for the Case

Alfred O.P. Leubert, pro se, New York, N.Y. John E. Becker, Jr. and William F. Halley, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioners for 1973 in the amount of $11,039. After concessions by petitioners, the following issues are for decision:

(1) Whether $15,000 of the $100,000 salary paid to petitioner-husband by his employer in 1973, which would not have been paid if he had his principal residence outside of Manhattan, is excludable under...

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