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JOHNS v. COMMISSIONER

Docket No. 12827-84.

53 T.C.M. 442 (1987)

T.C. Memo. 1987-163

George R.A. Johns and Beverly M. Johns v. Commissioner.

United States Tax Court.

Filed March 26, 1987.

Attorney(s) appearing for the Case

Michael E. Cozine, for the petitioners. Edward G. Martoglio and Marian L. Cannell, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined a deficiency of $9,179.02 in petitioners' 1980 Federal income tax.

The issues for decision are:

(1) Whether the container leasing activity of petitioner George R.A. Johns (petitioner)1 is devoid of economic substance and should therefore be disregarded for Federal income tax purposes;

(2) Whether petitioner's container leasing activity...

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