ABRAMS v. COMMISSIONER

Docket No. 82665.

21 T.C.M. 1039 (1962)

T.C. Memo. 1962-190

Morris Abrams v. Commissioner.

United States Tax Court.

Filed August 9, 1962.


Attorney(s) appearing for the Case

Abraham Baumgarten, Esq. 400 Madison Ave., New York, N. Y., and I. Robert Rozen, Esq., for the petitioner. Gerald J. Robinson, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in income tax in the amounts of $5,460.38 for the year 1949 and $3,092.42 for the year 1950.

The principal issue is whether losses sustained by petitioner as the result of advances to the El Paso Biltmore Corporation and Acme Television Service, Inc., and the payment as guarantor of a bank loan of the latter corporation, were deductible by him as losses sustained in the trade or business...

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