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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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Last modified: May 25, 2011