SMALLEY v. COMMISSIONER

Docket Nos. 4638-68, 4641-68.

32 T.C.M. 373 (1973)

T.C. Memo. 1973-85

Eleanore H. Smalley v. Commissioner. H. Earl Smalley v. Commissioner.

United States Tax Court.

Filed April 10, 1973.


Attorney(s) appearing for the Case

Wm. Royall Middelthon, Jr. and Woodrow M. Melvin, Jr., 1600 First Nat'l Bank Bldg., Miami, Fla., for the petitioners. W. Reeder Glass, for the respondent.


Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

In these consolidated cases the Commissioner determined deficiencies in the joint income tax liability of petitioners H. Earl Smalley, Jr., and Eleanore H. Smalley in the amount of $71,457.59 for 1960 and $2,048.14 for 1961, and issued separate statutory notices. Petitioners conceded the 1961 deficiency. We are asked to determine:

(1) The amounts of the net operating losses of two subchapter...

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