TODD v. COMMISSIONER

Docket No. 11212-79.

77 T.C. 246 (1981)

MALCOLM C. TODD AND RUTH S. TODD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 10, 1981.


Attorney(s) appearing for the Case

Ernest W. Pitney, for the petitioners.

Karl D. Zufelt, for the respondent.


WILES, Judge:

Respondent determined a deficiency of $24,238 in petitioners' 1972 income tax. The sole issue for decision is whether an abandonment loss incurred by petitioners in 1975 was attributable to a trade or business within the meaning of section 172(d)(4).1

FINDINGS OF FACT

All of the facts have been stipulated and are found accordingly.

Malcolm C. Todd (hereinafter petitioner) and Ruth S. Todd...

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