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DE GENNARO v. COMMISSIONER

Docket No. 785-79.

41 T.C.M. 284 (1980)

T.C. Memo. 1980-486

John E. De Gennaro and Gloria J. De Gennaro v. Commissioner.

United States Tax Court.

Filed October 28, 1980.

Attorney(s) appearing for the Case

Alan D. Pauw, 4075 Main St., Riverside, Calif., for the petitioners. Marshall W. Taylor, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax for the calendar year 1974 in the amount of $3,643.94. The sole issue for decision is whether petitioners sustained an ordinary loss or a capital loss upon the reconveyance of land, encumbered by a nonrecourse purchase money deed of trust, to their mortgagee/seller without any monetary consideration.

Findings of Fact...

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