GILFORD v. COMMISSIONER

Docket No. 29641.

11 T.C.M. 175 (1952)

Almy Gilford v. Commissioner.

United States Tax Court.

Entered February 27, 1952.


Attorney(s) appearing for the Case

Harry Friedman, Esq., 540 Munsey Bldg., Washington, D. C., for the petitioner Charles M. Greenspan, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

Respondent determined a deficiency in income tax for 1945 in the amount of $6,295.02, arising out of the disallowance of a claimed long-term capital loss carry-over from 1944. The loss arose from a sale of real property in 1944. The amount is not in dispute. The sole issue is whether the loss was capital or ordinary.

[The Facts]

Petitioner is an individual residing at 316 Lexington...

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