CITRON v. COMMISSIONER

Docket No. 626-88.

97 T.C. 200 (1991)

B. PHILIP CITRON AND EMILY K. CITRON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 5, 1991.


Attorney(s) appearing for the Case

Mortimer L. Laski, Kenneth G. Gordon, and Murray H. Falk, for the petitioners.

James S. Yan, for the respondent.


GERBER, Judge:

Respondent, in a statutory notice of deficiency, determined a $34,089 Federal income tax deficiency and a $1,704.45 addition to tax under section 6653(a)(1)1 for petitioners' 1981 taxable year. Respondent also determined an additional 50 percent of the interest due on the $34,089 deficiency under section 6653(a)(2) for the 1981 taxable year. The entire deficiency is attributable to the disallowance of a loss claimed...

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