LEVINE v. COMMISSIONER

Docket No. 57760.

31 T.C. 1121 (1959)

MAC LEVINE AND ANNE E. LEVINE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 27, 1959.


Attorney(s) appearing for the Case

George B. Lourie, Esq., and Arnold R. Cutler, Esq., for the petitioners.

Frank V. Moran, Jr., Esq., for the respondent.


Respondent determined deficiencies in petitioners' income tax for the years 1947, 1948, 1949, and 1950 in the respective amounts of $14,704.93, $1,178.02, $927.54, and $1,827.60. The only item in controversy is a part of the deficiency determination for 1947. The issues remaining are: (1) Whether petitioner Mac Levine's claims against his partly owned corporation became worthless in the tax year and whether they constituted a business or nonbusiness bad debt; or whether his...

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