- 13 - 24 Cal. 339, 345 (1864) (“[One who abandons property] must leave it free to the occupation of the next comer, whoever he may be, without any intention to repossess or reclaim it for himself in any event, and regardless and indifferent as to what may become of it in the future.”)). Instead, through a series of transactions, including the liquidation of Lever, petitioner effectively retained the partnership interest that he claimed to have abandoned. See Commissioner v. Clark, 489 U.S. 726, 738 (1989) (“interrelated yet formally distinct steps in an integrated transaction may not be considered independently of the overall transaction”); Commissioner v. Court Holding Co., 324 U.S. 331, 334 (1945). Consequently, petitioners are not entitled to a loss deduction in 1993 based upon petitioner’s surrender of the distributed partnership interest. It follows that petitioners are not entitled to the net operating loss carryover deductions here in dispute, and we so hold. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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