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BROWN v. COMMISSIONER

Docket No. 8581-77.

38 T.C.M. 91 (1979)

T.C. Memo. 1979-24

Milton O. Brown v. Commissioner.

United States Tax Court.

Filed January 16, 1979.

Attorney(s) appearing for the Case

Hugh L. Dick, for the petitioner. Jan R. Pierce, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency for the taxable year 1973 in the amount of $5,690. The issue remaining for decision is whether petitioner suffered an ordinary loss on section 12441 stock in the amount of $20,600 in 1973 within section 1244 of the Internal Revenue Code or whether he is entitled to a capital loss on worthless securities under section 165(g).

Findings...

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