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ALLISON v. COMMISSIONER

Docket No. 4958-86.

61 T.C.M. 2163 (1991)

T.C. Memo. 1991-115

James G. Allison, Jr. v. Commissioner.

United States Tax Court.

Filed March 18, 1991.

Attorney(s) appearing for the Case

Thomas E. Redding, 515 Post Oak Blvd., Houston, Tex., for the petitioner. Paul J. Krug and Jeffery N. Kelm, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:1

This case is before the Court on respondent's Motion for Judgment on the Pleadings. The basic facts relevant to respondent's motion are not in dispute and may be surprised as follows.

For the taxable year 1980, petitioner reported taxable income in the amount of $1,495,645 determined after claiming an ordinary loss on securities transactions in the amount of $2,416,891...

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