T.C. Memo. 1995-480
UNITED STATES TAX COURT
CHRISTINE C. DEIGNAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17309-93. Filed October 4, 1995.
Mark R. Schuling, for petitioner.
Jeffrey A. Schlei, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined deficiencies in
petitioner's Federal income taxes totaling $28,802 in 1986 and
$28,961 in 1989. At issue is whether a loss from the sale of
real estate should be characterized as ordinary or capital. The
parties agree that the resolution of this issue controls the
treatment of the loss carried back to 1986.
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