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ESTATE OF PALMER v. COMMISSIONER

Docket No. 29513.

17 T.C. 702 (1951)

ESTATE OF WILLIAM P. PALMER, JR., JEAN H. PALMER AND GEORGE H. P. LACEY, CO-EXECUTORS, AND JEAN H. PALMER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 25, 1951.

Attorney(s) appearing for the Case

George Farr, Jr., Esq., for the petitioners.

Cyrus A. Neuman, Esq., for the respondent.

The Commissioner determined a deficiency in income tax liability of William P. Palmer, Jr., deceased, and Mrs. Jean H. Palmer, surviving wife, in the amount of $13,745.89 for the calendar year 1946. The only issue presently in dispute is whether a bad debt in the amount of $33,661.64 representing uncollectible loans to Greenbrier Farms, Incorporated (hereinafter referred to as "Greenbrier Farms"), was a "non-business" bad debt within the meaning of section 23 (k) (4) of the...

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