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GROSS v. COMMISSIONER

Docket No. 6319-69.

31 T.C.M. 1098 (1972)

T.C. Memo. 1972-221

Irving A. Gross and Rosetta M. Gross v. Commissioner.

United States Tax Court.

Filed October 26, 1972.

Attorney(s) appearing for the Case

Gabriel T. Pap, 51 E. 67th, New York, N.Y., for the petitioners. Michael A. Menillo, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the calendar year 1966 in the amount of $2,220.87. Concessions have been made, leaving the following issues for our determination:

1. Whether the basis for computing a loss pursuant to section 165(a), Internal Revenue Code of 1954,1 on an...

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