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HOLLINGSWORTH v. COMMISSIONER

Docket No. 1642-77.

71 T.C. 580 (1979)

JOHN P. HOLLINGSWORTH AND JEAN L. HOLLINGSWORTH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 22, 1979.

Attorney(s) appearing for the Case

William S. Smith and Michael L. Campbell, for the petitioners.

Ronald M. Frykberg, for the respondent.

WILES, Judge:

Respondent determined a $8,850.68 deficiency in petitioners' 1974 Federal income tax. The sole issue is whether petitioners may deduct, as ordinary loss under section 165(a),1 $50,000 for a convertible subordinated note which became worthless in 1974.

FINDINGS OF FACT

Some facts were stipulated and are found accordingly.

John and Jean Hollingsworth...

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