DE COU v. COMMISSIONER

Docket No. 11226-91.

103 T.C. 80 (1994)

CHARLES H. DE COU AND MARTHA M. DE COU, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 27, 1994.


Attorney(s) appearing for the Case

Farley P. Katz, Michael W. Stukenberg, and Kenton E. McDonald, for petitioners.

Deborah H. Delgado, for respondent.


SWIFT, Judge:

Respondent determined a deficiency of $25,675 in petitioners' joint Federal income tax for 1985. The issue for decision is whether petitioners are entitled to an ordinary loss deduction under sections 165(a) and 167 with respect to losses associated with a building demolished in 1985.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.

FINDINGS OF FACT

Some...

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