HOFFMAN v. UNITED STATES

Civ. No. 65-562.

266 F.Supp. 884 (1967)

Lee HOFFMAN and Judy Hoffman, husband and wife, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court D. Oregon.

March 13, 1967.


Attorney(s) appearing for the Case

James R. Moore, Mautz, Souther, Spaulding, Kinsey & Williamson, Portland, Or., for plaintiff.

Jerome Fink, Attorney, Department of Justice, Washington, D. C., Sidney I. Lezak, U. S. Atty., Norman Sepenuk, Asst. U. S. Atty., Portland, Or., for defendant.


OPINION AND ORDER

SOLOMON, Chief Judge:

Plaintiffs, Lee and Judy Hoffman, seek to recover $9,345.61 in federal income taxes paid in their 1958 through 1961 joint returns. The case was submitted on stipulated facts.

The issue is whether the Hoffmans' payments to a bonding company are deductible as losses in a transaction entered into for profit under § 165(c) (2), Int. Rev.Code of 1954,

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