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SOWERBY v. COMMISSIONER

Docket No. 17170-81.

47 T.C.M. 897 (1984)

T.C. Memo. 1984-21

Delbert C. Sowerby and Florence Sowerby v. Commissioner.

United States Tax Court.

Filed January 11, 1984.

Attorney(s) appearing for the Case

Brian J. Van Voris, for the petitioners. Rebecca T. Hill, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent determined deficiencies of $16,466 and $12,873, respectively, for petitioners' 1977 and 1978 taxable years. After concessions by the petitioners, the issue for decision is whether petitioners are entitled to claim investment tax credits and depreciation on a sawmill they allegedly purchased and leased back, with option to buy, to the sellers.

Findings of Fact

Some of the...

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