CHILDS v. COMMISSIONER

Docket No. 993-66.

27 T.C.M. 322 (1968)

T.C. Memo. 1968-59

Henry A. Childs and Carol M. Childs v. Commissioner.

United States Tax Court.

Filed April 9, 1968.


Attorney(s) appearing for the Case

John H. Falsey, 425 Park Ave., New York, N. Y., for the petitioners. Charles M. Costenbader and Irving Bell, for the respondent.


Memorandum Findings of Fact and Opinion

HARRON, Judge:

The respondent determined for 1960 and 1961 income tax deficiencies of $5,669.83, and $4,283. Each deficiency results from respondent's disallowances of deductions in 1960 and 1961 of claimed loss carrybacks from 1963. The claimed net operating loss deductions were attributable to a loss sustained in 1963 from the worthlessness in 1963 of 915 shares of stock of Yankee Productions, Inc., a small business...

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