United States Tax Court September 14, 1981, Docket No. 15798-79 (Erfurth v. Commissioner)

lead-opinion

OPINION

Ekman, Judge:

Respondent determined a deficiency in petitioners’ Federal income tax for 1971 in the amount of $10,865.59. The sole issue for decision is whether petitioners may utilize nonbusiness capital losses in excess of nonbusiness capital gains to offset business capital gains in computing their net operating loss.