E.A. Brannen and Frances K. Brannen v. Commissioner of Internal Revenue

TUTTLE, Senior Circuit Judge:

Frances K. and E.A. Brannen, husband and wife, appeal from a decision of the United States Tax Court determining a deficiency in their joint federal income tax in the amount of $6,984.09 for the calendar year 1975. The opinion of the tax court is reported at 78 T.C. 471. We affirm,

I. FACTS

Dr. E.A. Brannen (“taxpayer”) 1 is a medical doctor by profession. In late February or early March 1974, the taxpayer attended a movie investment presentation at the home of a close friend. At the meeting, Dr. W.L. Ryder, a psychiatrist who represented himself as an investment…