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COOPER v. COMMISSIONER

Docket No. 13895-82.

45 T.C.M. 90 (1982)

T.C. Memo. 1982-658

John H. Cooper and Ruth Cooper v. Commissioner.

United States Tax Court.

Filed November 15, 1982.

Attorney(s) appearing for the Case

Edward Pesin, 744 Broad St., Newark, N.J., for the petitioners. Robert B. Marino, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This matter is before the Court on respondent's motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.

Respondent determined deficiencies in petitioners' Federal income taxes of $36,858 for 1977 and $34,475 for 1978. Included in the adjustment to income for 1977 made in the notice of deficiency is a claimed Schedule C loss of $73,600 which was disallowed by respondent...

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