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MARTIN v. COMMISSIONER

Docket No. 6561-66.

52 T.C. 140 (1969)

BERT W. MARTIN AND ADA L. MARTIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 23, 1969.

Attorney(s) appearing for the Case

Richard E. Murphy, Jr., and Warren C. Seieroe, for the petitioners.

Richard G. Daly, for the respondent.

OPINION

TIETJENS, Judge:

The Commissioner determined a deficiency in petitioners' 1964 income tax of $6,793.66. We must decide whether a $425,000 loss claimed by petitioner Bert W. Martin in 1964 is deductible under section 165(c)(2) of the Internal Revenue Code of 19541 as a loss incurred in a transaction entered into for profit.

The facts have been fully stipulated and are so found. The stipulation and the exhibits...

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