RICHARDS v. COMMISSIONER

Docket No. 4821-75.

35 T.C.M. 1709 (1976)

T.C. Memo. 1976-380

William D. Richards and Verna V. Richards v. Commissioner.

United States Tax Court.

Filed December 13, 1976.


Attorney(s) appearing for the Case

George L. Damoose, 701 Palomar Financial, San Diego, Calif., for the petitioners. Emory L. Langdow and Jeffrey C. Kahn, for the respondent.


Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined a deficiency in petitioners' federal income tax for the calendar year 1970 in the amount of $62,308.90.

Due to concessions, the sole remaining issue is whether petitioners' stock in Food Baron Corporation became worthless within the meaning of section 165(g)(1), I.R.C., 1954 during the taxable year at issue.

Findings of Fact

Some of the facts have been...

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