SCHOMBURG v. COMMISSIONER

Docket No. 37620.

13 T.C.M. 234 (1954)

William H. Schomburg v. Commissioner.

United States Tax Court.

Entered March 18, 1954.


Attorney(s) appearing for the Case

H. A. Mihills, Esq., 917 Munsey Building, Washington, D. C., and Robert J. Bird, Esq., for the petitioner. Robert E. Johnson, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined a deficiency in income tax for 1947 in the amount of $6,171.87. The questions to be decided are as follows: (1) Whether an indebtedness to petitioner of $13,750, which became worthless in 1947, was a business or a nonbusiness bad debt. The Commissioner determined that the indebtedness was a nonbusiness bad debt under section 23 (k) (4). (2) Whether the cost basis of stock...

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