SMITH v. COMMISSIONER

Docket No. 75315.

20 T.C.M. 412 (1961)

T.C. Memo. 1961-91

Lynn A. Smith and Mary McK. Smith v. Commissioner.

United States Tax Court.

Filed March 31, 1961.


Attorney(s) appearing for the Case

Richard G. Hahn, Esq., Security Bldg., Pasadena, California., for the petitioners. Michael P. McLeod, Esq. for the respondent.


Memorandum Findings of Fact and Opinion

TRAIN, Judge:

Respondent determined a deficiency in the petitioners' income tax for the year ended December 31, 1955, in the amount of $14,690.11.

The issues for determination are:

(1) Whether petitioner was engaged in the trade or business of promoting, organizing, forming, managing and financing business enterprises; and

(2) If he was, whether certain losses were incurred by petitioner in...

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