GALLUN v. COMMISSIONER

Docket No. 89500.

22 T.C.M. 798 (1963)

T.C. Memo. 1963-167

Edwin A. Gallun and Jane W. Gallun v. Commissioner.

United States Tax Court.

Filed June 14, 1963.


Attorney(s) appearing for the Case

Richard S. Gibbs and W. J. Roper for the petitioners. Vernon R. Balmes for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in the income tax of the petitioners for the calendar year 1956 in the amount of $19,827.19. Petitioners have conceded the issue raised in their petition with respect to the treatment of a loss sustained by them during the taxable year on an investment in a limited partnership.

The two issues remaining for decision are:

1. Whether the petitioner, Edwin...

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