A taxpayer may desire to recognize a loss by reason of diminution in value of property, in order to offset other income, but without effecting a full disposition of the property. Computer Sciences Corporation v. Commissioner (Tax Court Docket No. 4823-21) reflects such a situation.

The petitioner, Computer Sciences Corporation (CSC), entered into a series of transactions involving acquisition and sale of stock and a note of a subsidiary; the transactions were apparently intended to cause recognition of a capital loss to offset a capital gain realized by CSC in the same fiscal year.