SUGARMAN v. COMMISSIONER

Docket No. 88195.

21 T.C.M. 1018 (1962)

T.C. Memo. 1962-186

Leroy A. Sugarman v. Commissioner.

United States Tax Court.

Filed August 6, 1962.


Attorney(s) appearing for the Case

Leonard J. Schwartz, Esq., 1401 Walnut St., Philadelphia, Pa., and J. Victor O'Brien, Esq., for the petitioner. Frederick A. Levy, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

DRENNAN, Judge:

Respondent has determined a deficiency in income tax due from petitioner for the taxable year 1954 in the amount of $47,453.08.

The only issue for decision is whether petitioner is entitled to a deduction in 1954 in the amount of $94,892.73 representing a loss sustained on the abandonment of "royalty-yielding mineral rights."

Findings of Fact

Some of the facts have been stipulated...

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