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LUDWIG v. COMMISSIONER

Docket No. 27836-92.

68 T.C.M. 961 (1994)

T.C. Memo. 1994-518

Stanley J. Ludwig and Barbara Ludwig v. Commissioner.

United States Tax Court.

Filed October 17, 1994.

Attorney(s) appearing for the Case

Richard M. Henry, 100 Pacifica, Irvine, Calif., for the petitioners. Christine V. Olsen, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined an income tax deficiency of $7,473 against petitioners for 1990. Petitioners are husband and wife, but references hereinafter to petitioner in the singular are to the husband. Petitioners challenge the deficiency on the ground that they were improperly denied a deduction either as a business expense under section 1621 or as a loss under section 165 for payment in 1990...

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