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GANGEL v. COMMISSIONER

Docket No. 4522-86.

62 T.C.M. 319 (1991)

T.C. Memo. 1991-358

Richard Gangel v. Commissioner.

United States Tax Court.

Filed August 5, 1991.

Attorney(s) appearing for the Case

Marvin B. Segal, 41 Madison Ave., New York, N.Y., Peter W. Schmidt, 153 E. 53rd St., New York, N.Y., and Mark A. Berlin,1 for the petitioner. Drita Tonuzi and Paulette Segal, for the respondent.

FAY, Judge:

Respondent determined a deficiency in petitioner's Federal income tax in the amount of $36,748 for taxable year 1978. Respondent also determined section 6621(c)2 (formerly section 6621(d)) was applicable.

After concession,3 the issues remaining for decision are: (1) Whether petitioner is entitled to Schedule C losses and investment tax credits (ITC) stemming from his lithograph activities...

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