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STOODY v. COMMISSIONER

Docket No. 1127-73.

66 T.C. 710 (1976)

WINSTON STOODY AND SANDRA STOODY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 14, 1976.

Attorney(s) appearing for the Case

Thomas H. Carver, for the petitioners.

Darrell B. McDaniel, for the respondent.

IRWIN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1968 and 1969 in the amounts of $4,568 and $3,716, respectively. The sole issue raised in this litigation is whether payments made by Winston Stoody under a settlement agreement entered into to settle a lawsuit are deductible in full in the years of payment or are subject to the capital loss limitations of section...

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