LIGGETT'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 4911.

216 F.2d 548 (1954)

ESTATE of Harry M. LIGGETT, Deceased; Lucille W. Liggett, Executor; and Lucille W. Liggett, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Tenth Circuit.

November 1, 1954.


Attorney(s) appearing for the Case

Byron M. Gray, Topeka, Kan., for petitioners.

Walter Akerman, Jr., Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky and Robert B. Ross, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before PHILLIPS, Chief Judge, and BRATTON and HUXMAN, Circuit Judges.


HUXMAN, Circuit Judge.

This petition for review challenges the correctness of the decision of the Tax Court of the United States denying the right of Harry M. Liggett, now deceased, to deduct from his 1946 income as a bad debt deduction the sum of $47,000 represented by a note, under the provisions of Section 23(k) (1) of the Internal Revenue Code, 26 U.S.C.A.

The facts as found by the Tax Court may be summarized as follows: In February, 1946, Harry M. Liggett...

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