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FULLER v. COMMISSIONER

Docket Nos. 34450, 34451.

21 T.C. 407 (1953)

HADWEN C. FULLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. HADWEN C. FULLER AND EDITH R. FULLER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 30, 1953.

Attorney(s) appearing for the Case

Caleb Candee Brown, Jr., Esq., for the petitioners.

William G. O'Neill, Esq., for the respondent.

These consolidated proceedings involve deficiencies of $5,476.83 in the income tax of Hadwen C. Fuller for the year 1947, and $4,186.30 in the income tax of Hadwen C. Fuller and Edith R. Fuller for the year 1948.

The issue to be decided is whether certain worthless loans represented business or nonbusiness bad debts.

FINDINGS OF FACT.

The stipulated facts are so found and are incorporated herein.

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