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JOSEPH E. WIDENER, TRUST NO. 5 v. COMMISSIONER

Docket No. 2689-78, 2690-78.

80 T.C. 304 (1983)

JOSEPH E. WIDENER, TRUST No. 5, PROVIDENT NATIONAL BANK, TRUSTEE No. 56712, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT PETER A. B. WIDENER, TRUST No. 5, PROVIDENT NATIONAL BANK, TRUSTEE No. 65972, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 31, 1983.

Attorney(s) appearing for the Case

Thomas F. Cunnane and Thomas M. James, for the petitioners.

John W. Schmehl, for the respondent.

FORRESTER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for their fiscal years ending January 31, 1975, as follows:

             Docket No.                  Deficiency

              2689-78 ...............     $19,704
              2690-78 ...............      13,964

The question presented is whether petitioner trusts may recognize capital losses generated by various stock sales between...

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