CRUTTENDEN v. COMMISSIONER

Docket No. 9037-75.

37 T.C.M. 8 (1978)

T.C. Memo. 1978-4

Walter W. Cruttenden and Fay T. Cruttenden v. Commissioner.

United States Tax Court.

Filed January 3, 1978.


Attorney(s) appearing for the Case

Lewis M. Porter, Jr., Suite 2650, One IBM Plaza, Chicago, Ill., for the petitioners. Harmon B. Dow, for the respondent.


Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in Federal income tax for the taxable year 1971 in the amount of $12,644. The issues for decision are as follows:

1. Whether legal expenses paid by Petitioner Fay T. Cruttenden to recover securities from a brokerage firm of which she was a shareholder represent a loss on a transaction entered into for profit under section 165(c)(2),1<...

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