GUGGENHEIMER v. COMMISSIONER

Docket No. 8813.

8 T.C. 789 (1947)

CHARLES S. GUGGENHEIMER AND MINNIE S. GUGGENHEIMER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 9, 1947.


Attorney(s) appearing for the Case

Edgar J. Goodrich, Esq., Lipman Redman, Esq., and Edward First, Esq., for the petitioners.

Ellyne E. Strickland, Esq., for the respondent.


The Commissioner determined a deficiency of $7,388.47 in income tax for 1940, in part by disallowing the deduction of $38,927.91 claimed as a bad debt. Petitioner contends that this amount, representing the part of a partnership credit balance relinquished by him in a settlement agreement with his brother and sister, is deductible either as a bad debt or as a loss, since he had individually advanced funds reflected in the credit balance for the conduct of the partnership...

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