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CHRISTOPHER v. COMMISSIONER

Docket No. 13250-79.

48 T.C.M. 663 (1984)

T.C. Memo. 1984-394

William H. Christopher, Jr., and Lily Ann Christopher v. Commissioner.

United States Tax Court.

Filed July 30, 1984.

Attorney(s) appearing for the Case

Richard F. McDivitt and Kevin D. Watley, for the petitioners. Robyn R. Jones, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency in petitioners' 1976 Federal income tax in the amount of $5,863.55. After concessions, the issues for our decision are (1) whether petitioners recognized gain of $2,596.82 upon incorporation of William Christopher, Jr.'s sole proprietorship and (2) whether petitioners' pro rata share of the net operating loss of that corporation...

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