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PERRY v. COMMISSIONER

Docket No. 1018-64.

47 T.C. 159 (1966)

WILLIAM H. PERRY AND MARION E. PERRY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 18, 1966.

Attorney(s) appearing for the Case

William C. Myers, Jr., for the petitioners.

Hugh C. McMahon, for the respondent.

FORRESTER, Judge:

The respondent determined deficiencies in the petitioners' Federal income taxes for the calendar years 1960 and 1961 in the respective amounts of $3,324.18 and $2,118.96. Some concessions have been made, and the only issue for our decision is whether the petitioners' deductible share of the net operating losses incurred by an electing small business corporation exceeds the amounts allowed by the respondent.

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