Hackworth v. Commissioner, IRS

This case arises from the denial by the Commissioner of Internal Revenue of a $152,016 claimed loss deduction under I.R.C. § 165 by Edman and Debbie Kay Hackworth (“taxpayers”) on their 1999 income tax return. On February 22, 2002, the Commissioner issued a tax notice of deficiency to the taxpayers. The taxpayers timely filed a petition in the United States Tax Court seeking a redetermination of their liabilities. On July 22, 2004, the Tax Court issued a memorandum opinion and on October 15, 2004, entered a final decision determining tax liabilities and additions to tax against the taxpayers…