Marshall Long and Betty C. Long v. Commissioner of Internal Revenue

LOGAN, Circuit Judge.

Marshall Long and his wife Betty C. Long appeal from the judgment of the United States Tax. Court sustaining the Commissioner’s determination of income tax deficiencies on their 1971 and 1972 joint income tax returns. Marshall Long (taxpayer), a beneficiary of the estate of his father John C. Long, claimed deductions for his share of the estate’s alleged unused long-term capital losses incurred during administration of the estate and carried over to him under Internal Revenue Code (IRC) § 642(h). The only issues on appeal are whether John C. Long’s estate, which succeeded…