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RUSSELL v. COMMISSIONER

Docket No. 5272-79.

41 T.C.M. 954 (1981)

T.C. Memo. 1981-82

John C. and Virginia Russell v. Commissioner.

United States Tax Court.

Filed February 24, 1981.

Attorney(s) appearing for the Case

Philip J. O'Reilly, 800 Third Ave., New York, N.Y., for the petitioner. Martha Sullivan, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $7,491.90 in petitioners' Federal income tax for the taxable year ended December 31, 1975, and an addition to tax of $261.43 under section 6651(a)1 for the late filing of the return for that year. The issues involved are (1) the amount of loss, if any, which petitioner John C. Russell suffered from the disposition of certain stock...

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