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FINK v. COMMISSIONER

Docket No. 22865-80.

48 T.C.M. 786 (1984)

T.C. Memo. 1984-418

Peter R. Fink and Karla S. Fink v. Commissioner.

United States Tax Court.

Filed August 7, 1984.

Attorney(s) appearing for the Case

Mark K. Wilson, 100 Renaissance Center, Detroit, Mich., for the petitioners. Richard A. Witkowski, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioners' 1976 and 1977 Federal income taxes in the respective amounts of $131,885 and $133,826. After a concession by petitioners, the issues remaining for decision are whether they are entitled to loss deductions for their non pro rata surrender of stock to the issuing corporation, and, if so, the measure of such losses.

Findings of Fact

Some...

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