- 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
Last modified: May 25, 2011