SOUTHEASTERN AVIATION UNDERWRITERS, INC. v. COMMISSIONER

Docket No. 5366-63.

25 T.C.M. 412 (1966)

T.C. Memo. 1966-75

Southeastern Aviation Underwriters, Inc. v. Commissioner.

United States Tax Court.

Filed April 11, 1966.


Attorney(s) appearing for the Case

DeJongh Franklin and David J. Harris, Suite 509, Standard Federal Bldg., Atlanta, Ga., for the petitioner. Arthur P. Tranakos and George W. Calvert, for the respondent.


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income tax for the calendar years 1957, 1958, 1959, and 1960 in the respective amounts of $18,084.55, $25,585.81, $33,539.60, and $31,168.71.

The issue for decision is whether petitioner sustained a net operating loss in the year 1960 resulting from a deduction, as an ordinary and necessary business...

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