Birnbaum v. Commissioner

PAUL BIRNBAUM and REBECCA BIRNBAUM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Birnbaum v. Commissioner

Docket No. 1713-77.

United States Tax Court

T.C. Memo 1978-429; 1978 Tax Ct. Memo LEXIS 85; 37 T.C.M. (CCH) 1775; T.C.M. (RIA) 78429;

October 30, 1978, Filed

William G. O'Neill, for the petitioners.

Louis Conti, for the respondent.

QUEALY

MEMORANDUM FINDINGS OF FACT AND OPINION

QUEALY, Judge: Respondent determined a deficiency for the taxable year 1973 in the amount of $ 24,554.

The sole issue remaining for decision is whether petitioners realized taxable income on account of a…