FRENTZ v. COMMISSIONER OF INTERNAL REVENUE

No. 16946.

375 F.2d 662 (1967)

J. William FRENTZ et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

March 7, 1967.


Attorney(s) appearing for the Case

Arthur Clark, Jr., Cincinnati, Ohio, for petitioners, Frank E. Haddad, Jr., Louisville, Ky., on the brief.

Robert I. Waxman, Dept. of Justice, Washington, D. C., for respondent, Richard M. Roberts, Acting Asst. Atty. Gen., Lee A. Jackson, Gilbert E. Andrews, Attys., Dept. of Justice, Washington, D. C., on the brief.

Before EDWARDS, CELEBREZZE and PECK, Circuit Judges.


ORDER.

Petitioners claimed as deductions in their 1960 income tax returns their pro rata shares of losses sustained by Kentuckiana Broadcasting, Inc., an electing small business corporation under Subchapter S of the Internal Revenue Code of 1954, during the fiscal year ending October 31, 1960. The required election in the name of Kentuckiana was filed by petitioners, along with their consent as shareholders, on November 30, 1959. Kentuckiana's charter was issued by...

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