WILLIAMS v. COMMISSIONER

Docket No. 2190-67.

29 T.C.M. 1347 (1970)

T.C. Memo. 1970-292

Sylvester Hillary Williams and Sylvia Mae Williams v. Commissioner.

United States Tax Court.

Filed October 14, 1970.


Attorney(s) appearing for the Case

Sylvester Hillary Williams, pro se, 214 Tenafly Rd., Tenafly, N. J. Richard J. Mandell and Michael A. Menillo, for the respondent.


Memorandum Findings of Fact and Opinion

HOYT, Judge:

The respondent determined deficiencies in the petitioners' income taxes for the calendar years 1961 and 1962 in the amounts of $698 and $694.45, respectively.

The issues remaining in the case for our decision are as follows:

(1) Whether the petitioners may deduct $2,287 in the year 1961 under section 165 of the 1954 Code as a loss incident to a forfeiture.

(2) Whether the petitioners...

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