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BYRNE v. COMMISSIONER

Docket No. 603-64.

45 T.C. 151 (1965)

JOHN E. BYRNE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 5, 1965.

Attorney(s) appearing for the Case

William N. Brady, for the petitioner.

James E. Caldwell, for the respondent.

OPINION

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's income tax for the years 1959 and 1960 in the respective amounts of $557.58 and $3,807.63.

There are two issues for decision:

(1) Whether petitioner is entitled to deduct in the taxable years 1959 and 1960, net operating losses of J. J. Glenn & Co. (hereafter referred to as Glenn Co.), a corporation which elected...

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