BIERNBAUM v. COMMISSIONER

Docket Nos. 84651, 93135.

22 T.C.M. 1046 (1963)

T.C. Memo. 1963-210

Ralph and Helen Biernbaum v. Commissioner.

United States Tax Court.

Filed August 6, 1963.


Attorney(s) appearing for the Case

Sidney B. Palley, 133-11 231 St., Laurelton, N. Y., and Warren J. Kaps, for the petitioners. Gerald J. Robinson, for the respondent.


Memorandum Findings of Fact and Opinion

BRUCE, Judge:

The respondent determined deficiencies in income tax for the calendar years 1956 and 1957 in the respective amounts of $6,079.70 and $34,075.53. The sole issue as to each year is the amount of the net operating loss deduction, if any, available to the petitioners. The deduction claimed involves losses incurred in the years 1952 through 1955. Some facts are stipulated.

Findings of Fact

...

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