PURVIS v. COMMISSIONER

Docket No. 7983-73.

65 T.C. 1165 (1976)

RALPH E. PURVIS AND PATRICIA LEE PURVIS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 30, 1976.


Attorney(s) appearing for the Case

Ralph E. Purvis, pro se.

Robert J. Chicoine, for the respondent.


HALL, Judge:

Respondent determined a deficiency in petitioners' 1969 Federal income tax of $16,975.44. Other issues having been disposed of by mutual agreement, the three issues for decision are:

(1) Whether petitioners' interest costs incurred in purchasing stock on margin may be capitalized under section 266?1

(2) Assuming that such interest costs may be capitalized did petitioners make a valid election under section...

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