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SIMMONS v. COMMISSIONER

Docket No. 4509-77.

72 T.C. 1204 (1979)

DONALD C. SIMMONS AND NANCY T. SIMMONS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 26, 1979.

Attorney(s) appearing for the Case

Norman J. Voog, for the petitioners.

Thomas P. Dougherty, Jr., for the respondent.

STERRETT, Judge:*

Respondent determined a deficiency in petitioners' income taxes paid for their taxable year ended December 31, 1974, in the amount of $6,375. The only issue for our decision is whether petitioners' stock in a small business corporation qualified as section 1244 stock entitling them to an ordinary loss deduction on their disposition thereof during the taxable year in issue.

FINDINGS OF FACT

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