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BLOOMFIELD v. COMMISSIONER

Docket No. 2864-67.

52 T.C. 745 (1969)

NORRIS BLOOMFIELD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 4, 1969.

Attorney(s) appearing for the Case

Stanley E. Jennings, for the petitioner.

Brice A. Tondre, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's income tax for the years 1960, 1961, and 1962 in the amounts of $1,739.88, $3,825.82, and $3,146.62, respectively. The issues for our determination are whether petitioner is entitled under section 1651 to deduct the claimed net worth of a sole proprietorship as a loss as a result of bankruptcy proceedings and whether petitioner is...

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