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TONEY v. COMMISSIONER

Docket No. 29384-84.

51 T.C.M. 472 (1986)

T.C. Memo. 1986-69

John D. Toney, Sr. and Mary R. Toney v. Commissioner.

United States Tax Court.

Filed February 13, 1986.

Attorney(s) appearing for the Case

H. Lawrence Yancey, 212 Center St., Little Rock, Ark., for the petitioners. Howard P. Levine, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies1 in petitioners' Federal income tax as follows:

  Year                     Deficiency

  1976.................... $2,220.00
  1977 ...................  5,822.00

After concessions by both parties, the issue remaining for our decision is whether petitioners are entitled to ordinary loss deductions...

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