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BOND v. COMMISSIONER

Docket No. 21533.

14 T.C. 478 (1950)

ALLAN BOND AND EVELYN BOND, HIS WIFE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 24, 1950.

Attorney(s) appearing for the Case

F. Van S. Parr, Jr., Esq., for the petitioners.

Joseph F. Lawless, Esq., for the respondent.

The respondent determined a deficiency of $7,617.51 in petitioners' income tax for the year 1944, due, in part, to his disallowance of a net operating loss carry-over of $110,070.98 under section 122 of the Internal Revenue Code. The petitioners plead, in the alternative, that, if the deduction is not allowable as a net loss carry-over from 1943, it should be allowed as a long term capital loss, due to the worthlessness of the stock...

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