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JAFFE v. COMMISSIONER

Docket Nos. 2903-66, 2904-66.

26 T.C.M. 1063 (1967)

T.C. Memo. 1967-215

Isidor Jaffe and Anna Jaffe v. Commissioner. Samuel Jaffe and Bette Jaffe v. Commissioner.

United States Tax Court.

Filed October 30, 1967.

Attorney(s) appearing for the Case

Bruce I. Hochman, for the petitioners. Marion Malone, for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in income tax for 1959 in the following amounts:

  Isidor and Anna Jaffe ........   $ 8,867.82
  Samuel and Bette Jaffe .......    12,425.27

The sole issue is whether losses sustained in 1962 by Isidor and Samuel, primarily in connection with loans or guarantees of loans to their wholly owned corporation, were business...

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