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ABRAMS v. COMMISSIONER

Docket No. 6159-78.

42 T.C.M. 355 (1981)

T.C. Memo. 1981-355

Sanford L. and Sandra M. Abrams v. Commissioner.

United States Tax Court.

Filed July 9, 1981.

Attorney(s) appearing for the Case

Sanford L. Abrams, pro se. Stanley H. Smith, Jr. and Mark W. Nickerson, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the year 1975 in the amount of $1,421.52. The sole issue for decision is whether petitioners sustained an ordinary loss or a capital loss upon the voluntary reconveyance of real property, encumbered by a nonrecourse purchase money mortgage, to their mortgagee/sellers without any monetary consideration.

Findings of Fact...

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