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SMYTHE v. COMMISSIONER

Docket No. 9805-83.

51 T.C.M. 158 (1985)

T.C. Memo. 1985-624

James T. Smythe and Judith M. Smythe v. Commissioner.

United States Tax Court.

Filed December 26, 1985.

Attorney(s) appearing for the Case

James T. Smythe, pro se. Nancy W. Hale, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1978 and 1979 in the amounts of $6,803.26 and $3,196.74, respectively. The issue for decision is whether petitioners are entitled to an investment tax credit under section 46(e)(3)(B)1 with respect to equipment purchased from and then leased to a corporation the stock of which was owned entirely by petitioners...

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