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ESTATE OF CAPORELLA v. COMMISSIONER

Docket No. 5213-83.

86 T.C. 285 (1986)

ESTATE OF JOSEPH CAPORELLA, DECEASED, NICK A. CAPORELLA, PERSONAL REPRESENTATIVE, AND JEAN CAPORELLA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 4, 1986.

Attorney(s) appearing for the Case

Theodore F. Brill, for the petitioners.

William V. Spatz and W. Robert Abramitis, for the respondent.

JACOBS, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

Tax year                       Amount of deficiency

1973 ..........................    $20,222.56
1974 ..........................        318.00
1977 ..........................      2,987.35

The 1973 and 1974 deficiencies are attributable to the partial disallowance of a net operating loss carryback from 1976.

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