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PARSON v. COMMISSIONER

Docket No. 6331-71.

33 T.C.M. 789 (1974)

T.C. Memo. 1974-183

B. James Parson and Lorraine C. Parson v. Commissioner.

United States Tax Court.

Filed July 10, 1974.

Attorney(s) appearing for the Case

M. Nelson Enmark, for the petitioners. Peter D. Bakutes, for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined deficiencies in petitioners' income tax as follows:

  Year                   Deficiency

  1963 ................. $ 3,571.53
  1964 .................  10,901.00

At issue is the extent of deductibility of a 1966 net operating loss of an electing small business corporation which its sole stockholder carried back to 1963 and 1964. Section 1374(c)(2) of the 1954 Code limits...

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