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SEAY v. COMMISSIONER

Docket No. 22605-80.

45 T.C.M. 1148 (1983)

T.C. Memo. 1983-175

Kenneth L. Seay and Myra W. Seay v. Commissioner.

United States Tax Court.

Filed March 31, 1983.

Attorney(s) appearing for the Case

R. Braxton Hill III, 1530 Virginia National Bank Bldg., Norfolk, Va., for the petitioners. Scott D. Anderson, for the respondent.

Memorandum Opinion

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' 1975 and 1976 Federal income tax in the amounts of $46,731 and $4,563, respectively.

The sole issue is the amount of the deduction to which petitioners are entitled on account of a net operating loss incurred by Kenneth's subchapter S corporation in 1975.1

This case was submitted fully stipulated pursuant to Rule 122, Tax Court...

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