T.C. Memo. 1999-336
UNITED STATES TAX COURT
MARGARET HANCOCK, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20107-97. Filed October 7, 1999.
John F. Daniels III, for petitioner.
Doreen M. Susi, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioner's Federal income taxes of $70,132 for 1993 and $63,075
for 1994.
After concessions, the sole issue for decision is whether
petitioner's losses from the sale of residential lots of $207,850
in 1993 and $166,599 in 1994 were capital losses, as respondent
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