BORG v. COMMISSIONER

Docket No. 2395-66.

50 T.C. 257 (1968)

JOE E. BORG AND RUTH P. BORG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 7, 1968.


Attorney(s) appearing for the Case

Charles A. Whitebook, for the petitioners.

Walter O. Johnson, for the respondent.


FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' 1962 joint Federal income tax of $3,844.18. Both parties having conceded certain issues, the sole issue remaining for decision is whether petitioners' deductible share of the net operating losses incurred by an electing small business corporation exceeds the amounts allowed by the respondent.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The...

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