Christopher Y. Kimm - Page 1

                                 T.C. Memo. 2003-215                                  


                               UNITED STATES TAX COURT                                


                         CHRISTOPHER Y. KIMM, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4102-01.               Filed July 17, 2003.                 

               Steve Mather and Stephen J. Mihaly, for petitioner.                    
               Jean Song, for respondent.                                             


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               VASQUEZ, Judge:  Respondent determined a $9,717 deficiency             
          in petitioner’s Federal income tax for 1996.  The issues for                
          decision are (1) whether Christopher Y. Kimm (petitioner) is                
          entitled to deduct a $30,000 payment to his father in 1996 as an            
          ordinary and necessary business expense under section 162 and (2)           







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