ANGEVINE v. COMMISSIONER

Docket No. 26105.

10 T.C.M. 1028 (1951)

Fred R. Angevine v. Commissioner.

United States Tax Court.

Entered October 23, 1951.


Attorney(s) appearing for the Case

Paul G. Reilly, Esq., and Francis R. Curry, Esq., for the petitioner. Thomas R. Charshee, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in income tax of the petitioner for 1945 in the amount of $8,405.82. The only issue for decision is whether a debt in the amount of $120,426.10 which became worthless in 1945 was a business or non-business bad debt within the meaning of section 23 (k) of the Internal Revenue Code.

Findings of Fact

The petitioner was engaged in the practice of law from 1912 through...

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