SMITH v. COMMISSIONER

Docket No. 7289-82.

48 T.C.M. 135 (1984)

T.C. Memo. 1984-268

Spencer A. Smith and Geneva W. Smith v. Commissioner.

United States Tax Court.

Filed May 21, 1984.


Attorney(s) appearing for the Case

Spencer A. Smith and Geneva W. Smith, pro se, Ringgold, Ga. Bonnie L. Cameron, for the respondent.


Memorandum Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax for taxable years 1978 and 1979 in the amounts of $1,255 and $2,907, respectively. The only issue for decision is whether petitioners are entitled to deductions in taxable years 1978 and 1979 under section 1721 for net operating loss carryovers from 1977.

All of the facts have been stipulated and this case was...

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