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MILLER v. COMMISSIONER

Docket No. 2667-86.

57 T.C.M. 46 (1989)

T.C. Memo. 1989-153

Samuel G. Miller and Jean D. Miller v. Commissioner.

United States Tax Court.

Filed April 10, 1989.

Attorney(s) appearing for the Case

C. Christopher Trower, 1600 Citizens Plaza, Louisville, Ky., and Scott W. Dolson, for the petitioners. Andrew M. Winkler, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By a notice of deficiency dated November 18, 1985, respondent determined a deficiency in petitioners' Federal income tax in the amount of $41,952.45 for taxable year 1980. After concessions, the sole issue for our consideration is whether petitioners are entitled to claim an ordinary loss with respect to small business stock pursuant to section 1244.1

Findings of...

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