STEEL, District Judge.
Plaintiffs, husband (hereinafter "taxpayer") and wife, filed a joint federal income tax return for 1960 and claimed as a deduction a $36,966.03 operating loss incurred in 1960 by Foxcatcher Livestock Company, a corporation, all of the stock of which was owned by taxpayer in 1960. Foxcatcher was a "small business corporation" (hereinafter "Sub-chapter S corporation"), as defined in 26 U.S.C. § 1371(a).
Sub-chapter S was added to...
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