Fred G. Meyer and Bessie Meyer, Cross-Appellants v. Commissioner of Internal Revenue, Cross-Appellee

After a careful and full consideration of the record and the briefs, it is our opinion that the judgment of the Tax Court should be affirmed. The memorandum opinion of the Tax Court is attached hereto as Appendix A.

APPENDIX A

MEMORANDUM OPINION

TIETJENS, Judge: The Commissioner determined a deficiency in petitioners’ Federal income tax for the taxable years 1970 and 1971 in the amounts of $25,861 and $973 respectively.

The issues remaining for determination are (1) whether the uncollectible portion of a judgment obtained by petitioners against a broker in a suit for recision is a loss under…