HOLTZ v. COMMISSIONER OF INTERNAL REVENUE

No. 15755.

256 F.2d 865 (1958)

Merriman H. HOLTZ and Helene Tyroll Holtz, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

June 12, 1958.


Attorney(s) appearing for the Case

Moe M. Tonkon, Portland, Or., for appellants.

Charles K. Rice, Asst. Atty. Gen., Melvin L. Lebow, Lee A. Jackson, Harry Baum, Attorneys, Department of Justice, Washington, D. C., for appellee.

Before POPE, BARNES and HAMLEY, Circuit Judges.


BARNES, Circuit Judge.

This is a petition for review of a Tax Court decision sustaining the Commissioner's determination of deficiencies in income taxes of the petitioners (husband and wife, herein referred to as petitioner) for the years 1949 and 1950. Petitioner, as guarantor of certain corporate obligations, sought to deduct as business bad debts (26 U.S.C. § 23, Internal Revenue Code of 1939 § 23(k) (1)) certain amounts he was compelled to pay...

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