FERGUSON v. COMMISSIONER

Docket No. 26482.

16 T.C. 1248 (1951)

A. KINGSLEY FERGUSON, LOIS C. FERGUSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 31, 1951.


Attorney(s) appearing for the Case

Richard R. Hollington, Esq., for the petitioners.

Thomas V. Lefevre, Esq., for the respondent.


The respondent determined a deficiency of $7,991.48 in the income tax liability of the petitioners for the calendar year 1947 and the entire amount thereof is in controversy.

The first assignment of error raises the question of whether a debt of $32,342.91 which became worthless in 1947 is deductible in its entirety under section 23 (k) (1), as claimed by petitioners, or whether it constituted a "nonbusiness debt" within the meaning of section 23 (k) (4) and, therefore...

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