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McLARNEY v. COMMISSIONER

Docket Nos. 4196-80, 11506-81.

44 T.C.M. 752 (1982)

T.C. Memo. 1982-461

Patrick Edward McLarney and Kathryn Colver McLarney v. Commissioner.

United States Tax Court.

Filed August 9, 1982.

Attorney(s) appearing for the Case

Patrick Edward McLarney, pro se, Bound Brook, N.J. Antonio R. Espinosa, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined the following deficiencies in petitioners' federal income tax:

  Docket No.    Tax Year    Deficiency

   4196-80       1977        $2,411
  11506-81       1978         2,818

After a concession by respondent the issue for our decision is whether sections 280A and 1831 limit the deductibility of losses from petitioners' boat chartering...

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