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PACIFIC SECURITIES v. COMMISSIONER

Docket No. 3806-89.

63 T.C.M. 2060 (1992)

T.C. Memo. 1992-90

Pacific Securities, John Wertin, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed February 12, 1992.

Attorney(s) appearing for the Case

Louis A. Huskins, 1800 Avenue of the Stars, Los Angeles, Calif., for the petitioner. Mary Tseng and Carl Inskeep, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

The instant case is a proceeding under section 6226 for a readjustment of partnership items of Pacific Securities (the partnership) for the taxable year ending December 31, 1983. Respondent issued a Notice of Final Partnership Administrative Adjustments in which he (1) disallowed an ordinary loss of $1,037,520 arising from the write-down under section 1.471-5, Income Tax Regs., of securities held by the...

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