O'MADIGAN v. COMMISSIONER

Docket No. 66433.

19 T.C.M. 1178 (1960)

T.C. Memo. 1960-212

Daniel O'Madigan, Jr., and Marjorie O'Madigan v. Commissioner.

United States Tax Court.

Filed October 7, 1960.


Attorney(s) appearing for the Case

Carl E. Starkloff, Esq., 4053 Lindell Blvd., St. Louis, Mo., for the petitioners. Robert B. Pierce, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in income tax for 1954 in the amount of $1,046.46, and made an addition to the tax of $739.07 for a substantial underestimation of estimated tax under section 294(d)(2), 1939 Code. The questions for decision are as follows: (1) Whether petitioner sustained an ordinary loss in a transaction entered into for profit under section 165(c)(2), 1954 Code, upon the termination of his employment...

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