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FRANCIS v. COMMISSIONER

Docket No. 2767-67.

27 T.C.M. 822 (1968)

T.C. Memo. 1968-170

Frank A. Francis, Therese H. Francis v. Commissioner.

United States Tax Court.

Filed August 5, 1968.

Attorney(s) appearing for the Case

Frank A. Francis, pro se, 50 State St., Hartford, Conn. Alan I. Weinberg, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

The respondent determined a deficiency in petitioners' income tax for the taxable year 1963 in the amount of $413.18. Due to certain concessions by petitioners, two issues remain for our decision:

1. Are the petitioners entitled to deduct as a loss a $1,214.08 payment as a guarantee against loss to a theater which had agreed to donate proceeds of a showing...

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