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SIMMONS v. COMMISSIONER

Docket No. 1891.

4 T.C. 478 (1944)

GRANT G. SIMMONS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 15, 1944.

Attorney(s) appearing for the Case

Frederick F. Rehberger, Esq., and James B. Burke, Esq., for the petitioner.

Lawrence F. Casey, Esq., for the respondent.

This proceeding involves a deficiency in income tax for the year 1940, determined by the Commissioner in the amount of $6,695.34. Certain minor adjustments in the notice of deficiency are not contested by the petitioner. The sole issue is whether the sum of $10,000, or some part thereof, subscribed by petitioner under a subscription agreement, is deductible as a bad debt under the provisions of section 23 (k) of the Internal Revenue...

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