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FOUST v. COMMISSIONER

Docket No. 7864-92.

70 T.C.M. 928 (1995)

T.C. Memo. 1995-481

Oliver Q. Foust and Talietha Foust v. Commissioner.

United States Tax Court.

Filed October 4, 1995.

Attorney(s) appearing for the Case

Oliver Q. Foust, pro se. Thomas M. Rohall, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency in petitioners' 1988 Federal income tax of $40,558.

The issues for decision are: (1) Whether petitioners have substantiated the basis of their stock in Vosburg Hotels, Inc., a "small business corporation" under section 1366,1 so as to enable them to claim a deduction for an ordinary loss of $129,083 and a deduction pursuant to section...

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