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KOEHN v. COMMISSIONER

Docket No. 26575.

16 T.C. 1378 (1951)

RICHARD P. KOEHN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 19, 1951.

Attorney(s) appearing for the Case

L. Warren Baker, C. P. A., for the petitioner.

Jackson L. Bailey, Esq., for the respondent.

OPINION.

JOHNSON, Judge:

Respondent determined a deficiency in income tax for the calendar year 1947 in the amount of $444.63. The sole issue is whether petitioner, who successively sold two personal residences in 1947, may offset the amount of gain realized from the sale of one by the amount of loss sustained from the sale of the other. Petitioner concedes other issues raised by the petition and other adjustments made in the notice of deficiency...

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