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ALBRIGHT v. COMMISSIONER

Docket No. 9591-82.

50 T.C.M. 1068 (1985)

T.C. Memo. 1985-485

Robert B. Albright v. Commissioner.

United States Tax Court.

Filed September 17, 1985.

Attorney(s) appearing for the Case

Bruce R. Lowry and James H. Stethem, 2000 Courthouse Plaza, Dayton, Ohio, for the petitioner. Mary Helen Weber, for the respondent.

Memorandum Opinion

GERBER, Judge:*

Respondent determined a deficiency in petitioner's Federal income tax of $16,588.88 for 1977 and $77,096.92 for 1978. The issues for decision are: (1) Whether capital was a material income-producing factor in petitioner's real estate partnerships so as to subject him to the 30-percent limitation of section 13481 and (2) whether guaranteed payments from the partnerships...

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