Collins v. Commission

Edward H. Howell, Judge.

Plaintiffs claimed a loss in 1966 when their stock in Mediphone, Inc. became worthless. The commission disallowed most of the loss deduction and plaintiffs appealed.

The facts have been stipulated.

In 1964 plaintiffs purchased (and still hold) $5,000 worth of stock in Mediphone, Inc., an Oregon corporation. During 1966 the stock became worthless and plaintiffs deducted the entire amount from their 1966 personal income tax return. The commission disallowed the deduction on the ground that when Oregon enacted the capital gains provision of the Internal Revenue Code, it…