FARRELL v. COMMISSIONER

Docket Nos. 94918, 94919.

22 T.C.M. 239 (1963)

T.C. Memo. 1963-60

J. A. Farrell and Doris Farrell v. Commissioner. Elmer C. Farrell and Dorothy Farrell v. Commissioner.

United States Tax Court.

Filed February 28, 1963.


Attorney(s) appearing for the Case

Dougal C. Pope, Esq., 404 American Investors Bldg., Houston, Tex., for the petitioners. Lyle Walker, Esq., and Robert L. Liken, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined deficiencies in the income tax for the taxable year 1957 of the petitioners J. A. Farrell and Doris Farrell in the amount of $1,578.93 and of the petitioners Elmer C. Farrell and Dorothy Farrell in the amount of $1,675.56.

The issues are whether the Farrell partnership is entitled to a deduction of $10,426.75 as a loss, or alternatively, as an ordinary and necessary...

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