Desta Taye-Channell and Bruce C. Channell - Page 15

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          Conclusion                                                                  
               We sustain respondent’s determination in the notice of                 
          deficiency, decreasing petitioners’ income by the amount of                 
          bartering services income reported and disallowing a section 44             
          credit and a section 162 deduction.  As we conclude that                    
          petitioners are not entitled to a section 44 credit or a section            
          162 deduction, it is unnecessary for us to decide the proper                
          valuation of the program.                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          



























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