HUDSON v. COMMISSIONER

Docket No. 61391.

31 T.C. 574 (1958)

PHIL L. HUDSON AND GERTRUDE HUDSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 23, 1958.


Attorney(s) appearing for the Case

Ivan Irwin, Esq., and Wentworth T. Durant, Esq., for the petitioners.

S. B. Bradley, Esq., for the respondent.


Respondent determined a deficiency of $14,477.22 in petitioners' income tax for 1952. The questions presented are: (1) Whether certain advances by petitioner to the H & K Manufacturing Company were loans or contributions to capital; (2) if the advances were loans, whether they are to be treated as business or nonbusiness bad debts upon becoming worthless; (3) if treated as business bad debts, whether they became worthless in 1952.

FINDINGS OF FACT.

Petitioners...

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