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RUSSELL v. COMMISSIONER

Docket No. 27660-87.

61 T.C.M. 2909 (1991)

T.C. Memo. 1991-269

James N. Russell and Marilyn B. Russell v. Commissioner.

United States Tax Court.

Filed June 12, 1991.

Attorney(s) appearing for the Case

Thomas J. Kennedy, 7th Floor, United Building, Salina, Kan., for the petitioners. Dale P. Kensinger, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax liability for the calendar year 1983 in the amount of $2,842. The sole issue for decision is whether petitioners are entitled to an investment tax credit under section 46(e)(3)(B)1 in connection with the purchase during 1983 of compressed gas cylinders for lease to unrelated parties. More specifically...

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