- 13 - Sec. 1001(a)-(c); Helvering v. Hammel, 311 U.S. 504 (1941). Petitioner argues that the IRS regulations and publications state that the sale or exchange of an interest in oil or gas produces ordinary, not capital, gain or loss. However, the interests foreclosed herein were not interests in oil or gas, but partnership interests. Petitioner has presented no evidence of unrealized receivables or inventory held by the partnerships, and thus the losses in issue in this case are capital losses. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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