SPILLERS v. C. I. R.

No. 26092.

407 F.2d 530 (1969)

Mance T. SPILLERS and Mary J. Spillers, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

February 21, 1969.


Attorney(s) appearing for the Case

E. Jackson Boggs, Albert C. O'Neill, Jr., of Fowler, White, Collins, Gillen, Humkey & Trenam, Tampa, Fla., for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Dept. of Justice, Lee A. Jackson, Atty., Dept. of Justice, Tax Div., Robert N. Anderson, Chester C. Davenport, Attys., Dept. of Justice, Lester R. Uretz, Chief Counsel, I.R.S., Washington, D. C., for respondent.

Before THORNBERRY and DYER, Circuit Judges, and KEADY, District Judge.


DYER, Circuit Judge:

This is a petition to review, pursuant to Section 7482 of the Internal Revenue Code of 1954, a decision by the Tax Court assessing income tax liabilities against the taxpayers Mance T. Spillers and Mary J. Spillers. They sought a redetermination in the Tax Court of asserted deficiencies in income tax for the years 1958, 1959 and 1961, claiming that a $50,000 loss suffered by them as owners of stock in a corporation which had become bankrupt should...

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