POKRESS v. COMMISSIONER

Docket No. 32205.

13 T.C.M. 805 (1954)

T. C. Memo. 1954-128

Louis N. Pokress and Lucille A. Pokress (Husband and Wife) v. Commissioner.

United States Tax Court.

Filed August 17, 1954.


Attorney(s) appearing for the Case

W. G. Ward, Esq., and Charles B. Costar, C. P. A., First National Bank Building, Miami, Fla., for the petitioners. James R. Harper, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in income tax of the petitioners for the year 1946 in the amount of $20,057.44. The contested issue is whether in the taxable year involved petitioners incurred a loss as a result of loans to Pappy's, Inc., a Florida corporation, and whether, if a loss was incurred, it was a business or a nonbusiness bad debt.

Findings of Fact

Petitioners, husband and wife, are residents...

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