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FLOOD v. COMMISSIONER

Docket No. 17066-82.

51 T.C.M. 458 (1986)

T.C. Memo. 1986-65

James J. Flood and Donna A. Flood v. Commissioner.

United States Tax Court.

Filed February 11, 1986.

Attorney(s) appearing for the Case

J. Flood, pro se, La Jolla, Calif. Irene Scott Carroll, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

With respect to petitioners' Federal income tax for 1978, respondent determined a deficiency of $13,036, and an addition to tax of $900.95 under section 6651(a)(1).1 After concessions, the issues for consideration are (1) whether certain stock issued to petitioner2 qualifies as section 1244 stock, (2) whether this stock became worthless in 1978...

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