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McDONOUGH v. COMMISSIONER

Docket No. 7612-75.

36 T.C.M. 213 (1977)

T.C. Memo. 1977-50

Bernard P. McDonough and Alma G. McDonough v. Commissioner.

United States Tax Court.

Filed February 28, 1977.

Attorney(s) appearing for the Case

G. Thomas Battle, for the petitioners. David W. Otto, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1972 and 1973 in the amounts of $35,638 and $90,286, respectively.

Due to concessions1 by petitioners the sole issue for decision is whether petitioners "incurred or continued" indebtedness to "purchase or carry" tax-exempt securities within the meaning of section 265...

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