SHERMAN v. COMMISSIONER

Docket No. 26522.

18 T.C. 746 (1952)

KATE BAKER SHERMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 18, 1952.


Attorney(s) appearing for the Case

Ralph L. McAfee, Esq., and William J. Nolan, Jr., Esq., for the petitioner.

William E. Murray, Esq., for the respondent.


Respondent determined a deficiency in income tax of the petitioner in the amount of $7,649.52 for the calendar year 1945, resulting from the disallowance of certain interest deductions and non-business bad debt losses claimed by the petitioner on her return.

The issues presented are as follows:

1. Is the petitioner entitled in 1945 to a capital loss carry-over from the year 1944 with respect to worthless debts which arose in that year as the result of payments...

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