United States Tax Court April 14, 1982, Docket No. 11372-77 (Pacella v. Commissioner)

lead-opinion

Nims, Judge:

Respondent determined deficiencies in petitioners’ Federal income taxes for the years 1971, 1972, and 1973, in the amounts of $17,980.80, $7,362.38, and $8,960.67, respectively. As a result of various concessions, the sole issue for decision is whether income attributable to petitioner Bernard L.