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THOMPSON v. COMMISSIONER OF INTERNAL REVENUE

No. 14775.

235 F.2d 599 (1956)

Elmer J. THOMPSON and Helen H. Thompson, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

June 22, 1956.

Attorney(s) appearing for the Case

Nathan J. Neilson, Los Angeles, Cal., for petitioner.

H. Brian Holland, Asst. Atty. Gen., Harry Marselli, Ellis N. Slack, A. F. Prescott, Stanley P. Wagman, Sp. Assts. to Atty. Gen., for respondent.

Before FEE and CHAMBERS, Circuit Judges, and FOLEY, District Judge.

FOLEY, District Judge.

Respondent Commissioner of Internal Revenue determined an income tax deficiency of $150 for each of the petitioners, Elmer J. Thompson and Helen H. Thompson, husband and wife, for the calendar year 1949. Their claims of bad debt loss arising out of transactions entered into in 1944 and 1946 with one Jack Miller were disallowed. The determinations of the Commissioner were sustained by the Tax Court of...

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