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MIDDLETON v. COMMISSIONER OF INTERNAL REVENUE

No. 82-8118.

693 F.2d 124 (1982)

Milledge L. MIDDLETON and Estate of Leone S. Middleton, Deceased, Milledge L. Middleton, Executor, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eleventh Circuit.

December 6, 1982.

Attorney(s) appearing for the Case

Robert M. Fink, Atlanta, Ga., for petitioners.

Kenneth W. Gideon, Chief Counsel, I.R.S., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, App. Sec., Gary R. Allen, R. Russell Mather, Tax Division, Dept. of Justice, Washington, D.C., for respondent.

Before HILL and VANCE, Circuit Judges, and TUTTLE, Senior Circuit Judge.

PER CURIAM:

This appeal presents the issue, as stated by the appellant, whether the losses resulting from the abandonment of real properties, each subject to nonrecourse debt in excess of the fair market value of the property, are capital losses subject to the limitations of §§ 1211 and 1212 of the Internal Revenue Code of 1954 or are ordinary losses under § 165 of the Internal Revenue Code of 1954.

The Tax Court held that when the owners of...

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