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CROWDER v. COMMISSIONER

Docket Nos. 30306, 30307.

19 T.C. 329 (1952)

RAY CROWDER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ALPHA CROWDER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 25, 1952.

Attorney(s) appearing for the Case

Benjamin L. Bird, Esq., for the petitioners.

W. B. Riley, Esq., for the respondent.

These proceedings were consolidated for hearing and involve deficiencies in income tax for 1946, $2,562.47 in Docket No. 30306, and $2,627.76 in Docket No. 30307. The issue is whether the amount of $6,909.68 paid to the Ray Crowder Service Insurance Company is deductible as an ordinary and necessary expense incurred in business or in the production of income, or, in the alternative, as a nonbusiness bad debt. Petitioners filed their...

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