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GAMBINO v. COMMISSIONER

Docket No. 30913-83.

52 T.C.M. 213 (1986)

T.C. Memo. 1986-383

Joseph Gambino and Catherine Gambino v. Commissioner.

United States Tax Court.

Filed August 18, 1986.

Attorney(s) appearing for the Case

Geoffrey J. O'Connor, for the petitioners. Laurence D. Ziegler and Thaddeus G. Wozny, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $36,169 in petitioners' Federal income tax for the taxable year ended December 31, 1979, and an addition to tax of $1,808 under section 6653(a).1 The issues for decision are whether petitioners are entitled to capital loss deductions for worthless stock and/or a worthless non-business bad debt, and whether they are subject to the...

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