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McDONNELL v. COMMISSIONER

Docket Nos. 5188-63, 754-64.

24 T.C.M. 647 (1965)

T.C. Memo. 1965-125

M. H. McDonnell and Opal McDonnell v. Commissioner.

United States Tax Court.

Filed May 11, 1965.

Attorney(s) appearing for the Case

Jimmie C. Dixon and George J. Petrovich, Jr., Rowan Bldg., Ft. Worth, Tex., for the petitioners. Williard A. Herbert, for the respondent.

Memorandum Findings of Fact and Opinion

TRAIN, Judge:

The respondent determined deficiencies in these consolidated proceedings for the years 1960, 1961, and 1962 in the respective amounts of $6,319.07, $6,524.37, and $3,035.72.

The sole issue for decision is whether the petitioners may deduct on their individual income tax returns for the years 1960-1962, inclusive, losses incurred by their ninety-nine-percent-owned corporation.

Findings...

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