ROLLINS v. COMMISSIONER

Docket No. 69941.

32 T.C. 604 (1959)

H. BEALE ROLLINS AND MARY E. ROLLINS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 10, 1959.


Attorney(s) appearing for the Case

Morris Fedder, Esq., for the petitioners.

William Schwerdtfeger, Esq., for the respondent.


DRENNEN, Judge:

Respondent has determined deficiencies in petitioners' income tax for the years 1952, 1953, and 1954 in the amounts of $11,362.24, $34,854.04, and $6,538.84, respectively.

The sole issue in respect to 1952 is whether the loss suffered from the worthlessness of a loan of $20,000 made to Manufacturers Research Corporation should be treated as a business or nonbusiness bad debt. In respect to 1953, the questions are: (1) Whether losses...

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