ADAMS v. COMMISSIONER

Docket No. 12238-78.

74 T.C. 4 (1980)

MARVIN R. ADAMS, JR., AND JEANNE H. ADAMS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 3, 1980.


Attorney(s) appearing for the Case

Joseph C. Ferrell, for the petitioners.

Avery B. Cousins III, for the respondent.


OPINION

DAWSON, Judge:

Respondent determined a deficiency of $22,995 in petitioners' Federal income tax for the year 1975.

At issue is whether petitioners can treat the loss on their corporate stock as an ordinary loss under section 12441 when the stock had been previously issued to a third party, later repurchased by the corporation which returned it to the status of authorized...

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