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JOVE v. COMMISSIONER

Docket No. 8378-72.

34 T.C.M. 710 (1975)

T.C. Memo. 1975-155

Ricardo Jove and Maria Rosa Jove v. Commissioner.

United States Tax Court.

Filed May 22, 1975.

Attorney(s) appearing for the Case

Herbert Stoller, 100 Wall St., N.Y., N.Y., for the petitioners. Walter C. Welsh, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency of $469.76 in petitioners' 1969 Federal income taxes. In addition, petitioners have claimed a refund of $9,023.44 of such taxes. Because of concessions by petitioners, the only issue before us is whether petitioners are entitled to deductions in 1969 under section 166(a)1 or section 162(a) for any part of an advance made by Ricardo...

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