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SANDERSON v. COMMISSIONER

Docket No. 17732-81.

50 T.C.M. 1033 (1985)

T.C. Memo. 1985-477

Walton W. Sanderson and Beverly Sanderson v. Commissioner.

United States Tax Court.

Filed September 12, 1985.

Attorney(s) appearing for the Case

Michael I. Sanders, Robert L. Deitz, Craig A. Emden, Jerald Pasternak, and Celia Roady, 1700 Pennsylvania Ave. N. W., Washington, D. C., for the petitioners. Alan C. Levine and Elizabeth S. Cassidy, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Chief Judge:

By notice of deficiency dated April 15, 1981, respondent determined a deficiency in petitioners' Federal income tax for the taxable year ended December 31, 1977 in the amount of $19,560. After concessions, the issues before us are: (1) whether petitioners' claimed share of Penn-Centennial Associates' losses should be disallowed because the transactions involving Penn-Centennial Associates lacked...

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