McDERMOTT v. COMMISSIONER

Docket No. 18443.

13 T.C. 468 (1949)

ARTHUR V. McDERMOTT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 30, 1949.


Attorney(s) appearing for the Case

Arthur V. McDermott, pro se.

Stephen P. Cadden, Esq., for the respondent.


This proceeding involves an income tax deficiency for the calendar year 1944 in the sum of $148.01.

The contested issue is whether petitioner is entitled to a nonbusiness bad debt deduction to the extent of $1,000, or is limited to the amount of $750 allowed by the respondent as a long term capital loss. This issue is resolved by the answer to the question of whether, when petitioner conveyed his one-eighth interest in certain real property to Emerson Holding Corporation...

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