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MOORE v. COMMISSIONER

Docket No. 16743-83.

85 T.C. 72 (1985)

JOSEPH F. MOORE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 25, 1985.

Attorney(s) appearing for the Case

Philip R. Linsley, Joseph F. Moore, pro se, and John E. Crooks, for the petitioner.

John O. Kent and Gregory A. Roth, for the respondent.

RAUM, Judge:

The Commissioner determined deficiencies in petitioner's Federal income taxes for 1979 and 1980 in the amounts of $11,845 and $7,618, respectively. The principal substantive issue for decision is whether the Commissioner erred in disallowing losses with respect to petitioner's purported activity as an "exclusive territorial distributor" of gemstones.

FINDINGS OF FACT

Some of the facts have...

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