DORFMAN v. C. I. R.

No. 273, Docket 31848.

394 F.2d 651 (1968)

Nat DORFMAN and Annette Dorfman, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided April 25, 1968.


Attorney(s) appearing for the Case

Paul Friedman, New York City, for petitioners.

Marco S. Sonnenschein, Atty., Dept. of Justice, Washington, D. C. (Lee A. Jackson, William A. Friedlander, Attys., and Mitchell Rogovin, Asst. Atty. Gen., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before MEDINA, MOORE and ANDERSON, Circuit Judges.


MEDINA, Circuit Judge:

Nat and Annette Dorfman appeal from a judgment of the Tax Court which held them liable for an income tax deficiency for the year 1960 amounting to $1,966.04 plus an addition to their tax for the same year of $98.30. The only issue involved on this appeal relates to the validity of Treasury Regulation 1.642 (h)-1(b), which effectively denied to petitioners the use of a capital loss carryover under Section...

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