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PROTZMANN v. COMMISSIONER

Docket No. 56428.

18 T.C.M. 462 (1959)

T.C. Memo. 1959-105

Henry Protzmann and Estate of Helga K. Protzmann, Deceased, Henry Protzmann, Executor v. Commissioner.

United States Tax Court.

Filed May 25, 1959.

Attorney(s) appearing for the Case

Robert S. Jones, Esq., for the petitioner. Raymond T. Mahon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in the income tax of Henry and Helga K. Protzmann for the year 1948 in the amount of $23,446.26, resulting from his disallowance of a deduction taken by them in their return for that year in the amount of $38,370.51 on account of a "Loss on brewing venture." Respondent determined that this "Loss on brewing venture" was "a nonbusiness bad debt as provided in section 23(k)(4) of the Internal...

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