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MEYER v. COMMISSIONER

Docket No. 1286-74.

34 T.C.M. 1525 (1975)

T.C. Memo. 1975-349

Fred G. Meyer and Bessie Meyer v. Commissioner.

United States Tax Court.

Filed December 8, 1975.

Attorney(s) appearing for the Case

Theodore W. Glocker, Jr., 1120 Florida Title Bldg., 110 W. Forsyth St., Jacksonville, Fla., for the petitioners. Donald W. Williamson, Jr., for the respondent.

Memorandum Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable years 1970 and 1971 in the amounts of $25,861 and $973 respectively.

The issues remaining for determination are (1) whether the uncollectible portion of a judgment obtained by petitioners against a broker in a suit for recision is a loss under section 165(c)(2), I.R.C. 1954,1 or a nonbusiness...

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