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PEREIRA v. COMMISSIONER

Docket Nos. 1178-74, 1276-74.

35 T.C.M. 290 (1976)

T.C. Memo. 1976-66

Alfredo F. Pereira and Maria E.S. Pereira v. Commissioner. Sandalio Suarez-Real v. Commissioner.

United States Tax Court.

Filed March 8, 1976.

Attorney(s) appearing for the Case

Vincent J. Brennan and Richard B. Wallace, 111 N.E. 1st, Miami, Fla., for the petitioners. David M. Berman, for the respondent.

[35 T.C.M. 291]

Supplemental Memorandum Opinion

RAUM, Judge:

These cases were originally submitted for decision on March 10, 1975. The sole matter in controversy was whether petitioners had timely filed elections pursuant to sections 172(b)(1)(D) and 172(b)(3)(C)(iii), I.R.C. 1954, to carry over Cuban expropriation losses suffered in 1960 to the years 1968, 1969, 1970 and 1971, the years in issue in these cases. The Memorandum...

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