James A. And Audrey J. Warner v. Commissioner of Internal Revenue, Jerrie D. And Leta J. Schooley v. Commissioner of Internal Revenue

HAMLIN, Circuit Judge:

This is an appeal from a decision of the Tax Court of the United States. The Tax Court’s opinion is reported at 48 T.C. 49. The Tax Court found that the petitioners had certain deficiencies in income tax for the taxable year of 1963 in that they reported certain losses as ordinary losses when they should have been reported as capital losses. The Tax Court had jurisdiction under 26 U.S.C. §§ 6212, 6213, 6214. We have jurisdiction over the appeal under 26 U.S.C. §§ 7482, 7483. The following facts give rise to this dispute:

Sewmor Sewing Center, Inc., was an Idaho…