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RODRIGUEZ-TORRES v. COMMISSIONER

Docket No. 5709-66.

29 T.C.M. 343 (1970)

T.C. Memo. 1970-76

Ramon Rodriguez-Torres and Gudelia Rodriguez-Torres v. Commissioner.

United States Tax Court.

Filed March 31, 1970.

Attorney(s) appearing for the Case

Albert B. Lewis and Leonard Alterwein 4 E. 43rd St., New York, N. Y. for the petitioners. Stanley J. Goldberg, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' 1964 Federal income tax in the amount of $1,089.82.

The only issue for decision is whether petitioners are entitled, under section 172 of the Internal Revenue Code of 1954,1 to a net operating loss carryover in 1964 for certain losses resulting from the confiscation or seizure by the Cuban Government...

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