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SELIGMAN v. COMMISSIONER

Docket Nos. 16854-82, 17467-82.

84 T.C. 191 (1985)

MILTON J. SELIGMAN AND ESTATE OF FRANCINE SELIGMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT FAYE S. HUTTON AND ESTATE OF C. HERBERT HUTTON, DECEASED, FAYE S. HUTTON, EXECUTRIX, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 12, 1985.

Attorney(s) appearing for the Case

O. Jan Tyler and Carl Abramson, for the petitioners.

John W. Dierker, for the respondent.

GOFFE, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes for the taxable years as follows:

Docket Nos.    1978          1979

 16854-82   $21,583.14   $14,130.78
 17467-82    11,842.85

After concessions by the parties, the issue for decision is whether petitioners2 are entitled to deduct under section 1623 certain...

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