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BARTER v. COMMISSIONER

Docket No. 35294-87.

59 T.C.M. 143 (1990)

T.C. Memo. 1990-142

H.H. Barter and Virginia Barter v. Commissioner.

United States Tax Court.

Filed March 19, 1990.

Attorney(s) appearing for the Case

Edward G. Maag, 123 Wedgewood Dr., Columbia, Ill., and Ronald D. Stanley, P.O. Box 422, Columbia, Ill., for the petitioners. Michael W. Bitner, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency of $464,208 in petitioners' 1980 income tax. After concessions, the issues remaining for decision are: (1) whether expenditures totaling $270,279 made by petitioner, H. H. Barter, are deductible as ordinary and necessary business expenses under section 1621 or must be treated as the nondeductible cost of acquiring a capital asset; and ...

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