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JARVIS v. COMMISSIONER

Docket No. 67492.

32 T.C. 173 (1959)

JAMES D. JARVIS AND MARY C. JARVIS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 22, 1959.

Attorney(s) appearing for the Case

Lester Fleming, Esq., for the petitioners.

Drew R. Tillotson, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined a deficiency in income tax and an addition to tax under section 294(d)(2) of the Internal Revenue Code of 19391 for the taxable year 1953 in the respective amounts of $3,062.26 and $297.59. The question in the case is whether certain loans made by petitioner to a corporation of which he was a stockholder, are deductible only as nonbusiness bad debts within the purview of section 23(k)(4...

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