MILGROOM v. COMMISSIONER

Docket No. 77329.

19 T.C.M. 1564 (1960)

T.C. Memo. 1960-285

Nathan Milgroom and Sadye Milgroom v. Commissioner.

United States Tax Court.

Filed December 30, 1960.


Attorney(s) appearing for the Case

James B. Muldoon, Esq., for the petitioners. Raymond T. Mahon, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined deficiencies in the petitioners' income tax for the years 1954 and 1955 in the respective amounts of $2,706.64 and $2,147.17. The issues are:

1. Whether loans in the amount of $44,027.80 made by petitioners to the Ellis Curtain Company and which became worthless in 1954 are deductible in that year as a business bad debt or as a nonbusiness bad debt; and

2....

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