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PFLUGER v. COMMISSIONER

Docket No. 30209-82.

51 T.C.M. 503 (1986)

T.C. Memo. 1986-78

Robert A. Pfluger and Elaine M. Pfluger v. Commissioner.

United States Tax Court.

Filed February 24, 1986.

Attorney(s) appearing for the Case

Joseph W. Weigel, for the petitioners. Thomas J. Kane, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $42,762 in the petitioners' Federal income tax for 1980 and an addition to tax of $2,138 under section 6653(a) of the Internal Revenue Code of 1954.1 The issues for decision are: (1) Whether the Commissioner's denial, for lack of substantitation, of all deductions claimed by the petitioners' family trust shifted

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