MARTIN v. COMMISSIONER

Docket No. 51062.

25 T.C. 94 (1955)

TONY MARTIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 24, 1955.


Attorney(s) appearing for the Case

J. Everett Blum, Esq., for the petitioner.

Joseph G. White, Esq., for the respondent.


The respondent determined a deficiency in income tax against petitioner for the calendar year 1949 in the amount of $4,506.62. Petitioner, by amended petition, claims an overpayment in an amount to be determined, if necessary, under a Rule 50 computation. The single question presented is whether a loss sustained by petitioner from an unpaid loan is to be deducted as a business bad debt or as a nonbusiness bad debt.

FINDINGS...

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