KLEPETKO v. COMMISSIONER

Docket No. 23973-88.

60 T.C.M. 1489 (1990)

T.C. Memo. 1990-644

Frank A. Klepetko v. Commissioner.

United States Tax Court.

Filed December 26, 1990.


Attorney(s) appearing for the Case

Lawrence Klepetko, 46 N. Washington Blvd., Sarasota, Fla., for the petitioner. Mark L. Hulse, for the respondent.


Memorandum Findings of Fact and Opinion

COLVIN, Judge:

Respondent determined a $26,660 deficiency in petitioner's Federal income tax for 1981. After concessions by petitioner, the remaining issues to be decided are:

1. Whether petitioner may deduct in 1981 the $38,958 he invested in TOPCO (a) as a loss from section 1244 stock, (b) as a bad debt under section 166, (c) as a business or investment expense under sections 162 or 212, or (d) as a loss...

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