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BRANUM v. COMMISSIONER

Docket No. 18178-90.

65 T.C.M. 1715 (1993)

T.C. Memo. 1993-8

Mansell W. Branum v. Commissioner.

United States Tax Court.

Filed January 11, 1993.

Attorney(s) appearing for the Case

William P. Bowers and Carolyn M. Beckett, for the petitioners. Martin M. Van Brauman, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined a deficiency in petitioner's Federal income tax in the amount of $1,006,569 for the tax year 1982.

A number of issues have been settled, and the only matter now in dispute is whether petitioner's election in his 1985 Form 1040 return to carry forward under section 172(b)(3)(C)1 "all [1985] losses" and forgo the "carryback of such losses to prior years" precludes...

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