MOORE v. COMMISSIONER

Docket No. 3025-76.

70 T.C. 1024 (1978)

JOHN M. AND BARBARA G. MOORE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 19, 1978.


Attorney(s) appearing for the Case

Lewis H. Mathis and Byron M. Eiseman, Jr., for the petitioners.

Barry M. Bloom and Charles M. Billings, for the respondent.


SIMPSON, Judge:

The Commissioner determined a deficiency of $2,757.23 in the petitioners' Federal income tax for 1972. Both parties have conceded certain adjustments. The issues remaining for decision are: (1) Whether, for Federal tax purposes, partners can agree to allocate retroactively partnership losses to a partner who was not a member of the partnership at the time such losses accrued; and (2) to what extent was a partnership loss incurred after the admission...

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