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CARTER v. COMMISSIONER

Docket No. 1515-77.

39 T.C.M. 456 (1979)

T.C. Memo. 1979-447

Charles W. and Jane D. Carter v. Commissioner.

United States Tax Court.

Filed November 8, 1979.

Attorney(s) appearing for the Case

Charles W. Carter, pro se, P.O. Box 226, Miller Place, N.Y. Joan Ronder Domike, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined a deficiency of $1,999.89 in petitioners' income tax for the taxable year 1972 and an addition to tax pursuant to section 6651(a)1 of $994.45.

Respondent has conceded that petitioners are not liable for the addition to tax. The only issue remaining is whether losses arising from two loans made...

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