THOMSON v. COMMISSIONER

Docket No. 3278-80.

46 T.C.M. 192 (1983)

T.C. Memo. 1983-279

Kenneth G. and Joan T. Thomson v. Commissioner.

United States Tax Court.

Filed May 19, 1983.


Attorney(s) appearing for the Case

Ronald T. Murphy, 5001 South Florida Ave., Lakeland, Fla., for the petitioners. William R. McCants, for the respondent.


Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $13,395.50 in the petitioners' income tax for 1974. The issue for decision is whether the petitioners had any basis in their stock in an electing small business corporation so that they could deduct their portion of a loss sustained by such corporation.

Findings of Fact

Some of the facts have...

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