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REICH v. COMMISSIONER

Docket No. 5357-76.

37 T.C.M. 729 (1978)

T.C. Memo. 1978-169

David Reich v. Commissioner.

United States Tax Court.

Filed May 4, 1978.

Attorney(s) appearing for the Case

David Reich, pro se. Richard S. Kestenbaum, for the respondent.

Memorandum Opinion

CHABOT, Judge:*

Respondent determined a deficiency of $56 in petitioner's 1974 income tax. Because of concessions by the parties, the only issue for decision is whether paragraphs (1) and (2) of section 1211(b)1 preclude the petitioner from deducting more than $500 on account of capital losses (in excess of capital gains).

All of the facts have been stipulated, and the stipulation...

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