NELSON v. COMMISSIONER

Docket No. 62593.

17 T.C.M. 888 (1958)

T.C. Memo. 1958-179

Frank Nelson, Jr., and Lee Etta Nelson v. Commissioner.

United States Tax Court.

Filed September 29, 1958.


Attorney(s) appearing for the Case

Lee C. Bradley, Jr., Esq., Comer Building, Birmingham, Ala., and John N. Wrinkle, Esq., for the petitioners. Frederick T. Carney, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined deficiencies in income tax for the years 1949 and 1950 in the amounts of $22,107.30 and $5,286.04,1 respectively.

The deficiency for each year is due to several adjustments only one of which (for each year) is in issue. The adjustment in issue (for each year) is the disallowance of losses in two wholly owned corporations as business bad debts under section 23(k...

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