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SHENKER v. COMMISSIONER

Docket No. 2989-78.

48 T.C.M. 164 (1984)

T.C. Memo. 1984-280

Morris A. Shenker and Lillian K. Shenker v. Commissioner.

United States Tax Court.

Filed May 24, 1984.

Attorney(s) appearing for the Case

John L. Boeger, 408 Olive Street, St. Louis, Mo., for the petitioners. James Kidd, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency in the amount of $251,919.01 in petitioners' joint 1971 Federal income tax.1 After concessions, the sole issue for decision is whether petitioners are entitled to a deduction under section 1652 for a purported loss sustained as a result of subordination agreements...

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