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MURRAY v. COMMISSIONER

Docket No. 1640-98.

80 T.C.M. 254 (2000)

T.C. Memo. 2000-262

Michael E. and Linda S. Murray v. Commissioner.

United States Tax Court.

Filed August 17, 2000.

Attorney(s) appearing for the Case

Robert H. Culton II, for the petitioners. Randall B. Pooler, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

This case was submitted to the Court without trial under Rule 122. Petitioners petitioned the Court to redetermine a $1,072,177 deficiency in their 1993 Federal income tax, a $268,044 addition thereto under section 6651(a)(1), and a $214,435 accuracy-related penalty under section 6662. Following concessions by the parties,1 we must decide whether petitioners may deduct a loss purportedly attributable...

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