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MAYS v. C. I. R.

Nos. 13784, 13785.

272 F.2d 788 (1959)

B. A. MAYS and Mildred Aleene Mays, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Harold A. MEARS and Rowena C. Mears, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

December 14, 1959.

Attorney(s) appearing for the Case

Clyde W. Key, Knoxville, Tenn., for petitioners.

Morton K. Rothschild, Washington, D. C. (Charles K. Rice, Lee A. Jackson, Robert N. Anderson, S. Dee Hanson, Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before McCALLISTER, Chief Judge, and MARTIN and MILLER, Circuit Judges.

MARTIN, Circuit Judge.

In these cases, which have been heard together, petitioners seek review of the United States Tax Court's decision disallowing deductions claimed by the taxpayers in 1952 for business bad debts under Section 23(k) (1) of the 1939 Internal Revenue Code, 26 U.S.C.A. § 23(k) (1).

Stipulated facts, including exhibits filed, have been adopted by the tax court as its findings of fact. These findings are unchallenged on this review. The...

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