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DUELL v. COMMISSIONER

Docket No. 78696.

19 T.C.M. 1381 (1960)

T.C. Memo. 1960-248

Charles H. Duell and Ruth P. Duell v. Commissioner.

United States Tax Court.

Filed November 23, 1960.

Attorney(s) appearing for the Case

E. Randolph Dale, Esq., 122 East 42nd Street, New York, N. Y., Walter W. Walsh, Esq., and George Berlstein, Esq., for the petitioners.

James E. Markham, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

ARUNDELL, Judge:

Respondent determined deficiencies in income tax for the taxable years ended December 31, 1954, 1955, and 1956 in the amounts of $2,909.62, $5,029.15, and $6,536.76, respectively.

The issue is whether petitioner Charles H. Duell sustained deductible losses under section 165 of the Internal Revenue Code of 1954, during the taxable years 1954, 1955, and 1956, by reason of the unconditional surrender...

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