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SEBRING v. COMMISSIONER

Docket No. 32875-87.

93 T.C. 220 (1989)

LESLIE W. SEBRING AND NANCI M. SEBRING, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 8, 1989.

Attorney(s) appearing for the Case

Jon F. Spadorcia and David M. Berry, for the petitioners.

Timothy S. Sinnott, for the respondent.

WILLIAMS, Judge:

Respondent determined deficiencies in petitioners' 1979 and 1981 Federal income tax of $9,690.23 and $14,020.60, respectively. The taxable year 1979 is in issue as a result of respondent's disallowance of a net operating loss carryback from 1982. The issues for decision are: (1) Whether petitioner Leslie Sebring, a bail bondsman, may deduct pursuant to section 1621 payments into accounts held as security for his...

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