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MANNARINO v. COMMISSIONER

Docket No. 80937.

23 T.C.M. 1476 (1964)

T.C. Memo. 1964-246

Samuel Mannarino and Rose Mannarino v. Commissioner.

United States Tax Court.

Filed September 18, 1964.

Attorney(s) appearing for the Case

Vincent M. Casey, for the petitioners. Charles A. Boyce, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency of $5,069.38 in the income tax of petitioners and an addition to tax of $140.80 for failure to pay estimated income tax for the calendar year 1956. The issues for decision are (1) whether petitioners are entitled to a deduction, under either section 165(c) or section 166(d), Internal Revenue Code of 1954,1 as a result of the worthlessness...

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