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PERKAL v. COMMISSIONER

Docket No. 5848-78.

50 T.C.M. 71 (1985)

T.C. Memo. 1985-272

Stuart Perkal and Pamela Perkal v. Commissioner.

United States Tax Court.

Filed June 6, 1985.

Attorney(s) appearing for the Case

Gerald H. Lean, 5700 Smith Ave., Baltimore, Md., for the petitioners. Susan B. Watson, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal individual income tax against petitioners for 1974 in the amount of $13,049. The issue for decision is whether stock issued by United Lite Company, Inc., to petitioner-husband qualifies as section 12441 stock, thereby entitling petitioners to ordinary loss treatment (rather than...

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