John E. Byrne v. Commissioner of Internal Revenue

CASTLE, Circuit Judge.

This petition for review of a Tax Court decision concerns income tax deficiencies determined against petitioner, John E. Byrne, 1 for the taxable years 1959 and 1960. The Commissioner of Internal Revenue determined that the taxpayer was not entitled to deductions claimed for those years as representing net operating losses. The Tax Court sustained the action of the Commssioner and entered its decision that there were deficiencies for such years in the amounts of $557.58 and $3,807.63, respectively. The taxpayer petitions for review.

The matter was heard before the Tax…