- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011