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GIBBONS v. COMMISSIONER

Docket No. 2239-70.

31 T.C.M. 949 (1972)

T.C. Memo. 1972-194

Eugene J. Gibbons and Dorothy G. Gibbons v. Commissioner.

United States Tax Court.

Filed September 6, 1972.

Attorney(s) appearing for the Case

Eugene J. Gibbons, pro se, 8750 Georgia Ave., Apt. 314B, Silver Spring, Md. James Q. Smith, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' income tax of $1,514.10 for the taxable year ended December 31, 1966 and $1,690.36 for the taxable year ended December 31, 1967. The sole issue is the availability of the unused portion of net operating losses for the taxable years 1963 and 1964, which, in turn, depends upon the validity of certain...

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