FUNKE v. COMMISSIONER

Docket No. 50356.

14 T.C.M. 585 (1955)

T.C. Memo. 1955-156

W. H. Funke and G. G. Funke v. Commissioner.

United States Tax Court.

Filed June 16, 1955.


Attorney(s) appearing for the Case

I. Harvey Levinson, Esq., 33 North La Salle Street, Chicago, Ill., for the petitioners. Andrew Kopperud, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined a deficiency in income tax of petitioners for the calendar year 1947 in the amount of $7,019.48.

The questions to be decided are (1) whether certain advances constituted loans or contributions to the capital of the Moody Brick & Tile Company; (2) whether the debt, if any, of the Moody Brick & Tile Company became worthless in 1947, and, if so, whether it was a non-business or a business...

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