BARRY v. COMMISSIONER

Docket No. 7629-71.

32 T.C.M. 1332 (1973)

T.C. Memo. 1973-280

Julian P. Barry and Florence T. Barry v. Commissioner.

United States Tax Court.

Filed December 26, 1973.


Attorney(s) appearing for the Case

James D. Webb, III, 10th Fl., 2001 Bryan Tower, Dallas, Tex., for the petitioners. Bernard B. Nelson, for the respondent.


Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined deficiencies in petitioners' income tax for the taxable year 1967 in the amount of $3,021.92. The issues for decision are:

(1) Whether the loss arising from a sale of stock is deductible under section 1651 of the Internal Revenue Code of 1954 as an ordinary or capital loss, and

(2) Whether amounts paid pursuant to a loan guaranty are deductible...

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