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THOMAS v. COMMISSIONER

Docket No. 29942-81.

84 T.C. 1244 (1985)

JAMES P. THOMAS AND MARY LOU THOMAS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 4, 1985.

Attorney(s) appearing for the Case

Elliot I. Miller and Richard S. Kestenbaum, for the petitioners.

Joseph A. Maselli, Patricia A. Donahue, and Michael Goldbas, for the respondent.

STERRETT, Chief Judge:

By notice of deficiency dated September 25, 1981, respondent determined a deficiency of $37,411 in petitioners' 1978 Federal income tax.1 The ultimate issue for decision is the amount, if any, that petitioners are entitled to deduct in 1978 for "mining development costs," "operating management fees," and "professional fees."

FINDINGS OF FACT

Some of the facts have been stipulated and are...

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