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LENAMON v. C. I. R.

No. 18770.

296 F.2d 844 (1961)

W. B. and Dorothy LENAMON, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

December 13, 1961.

Attorney(s) appearing for the Case

James F. Goodman, Waco, Tex., for petitioners.

Hart H. Spiegel, Chief Counsel, Rollin H. Transue, Sp. Atty., I. R. S., Washington, D. C., Abbott M. Sellers, Acting Asst. Atty. Gen., Lee A. Jackson, Atty. Dept. of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., I. Henry Kutz, Harold M. Seidel, Burt J. Abrams, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before TUTTLE, Chief Judge, and HUTCHESON and RIVES, Circuit Judges.

TUTTLE, Chief Judge.

This appeal from the Tax Court tests the correctness of its decision that the taxpayer failed to carry the burden of proof with respect to his claimed deductions in the form of additions to reserves for bad debts under Section 23(k)(1) of the 1939 Internal Revenue Code, 26 U.S. C.A. § 23(k)(1).

The Statute involved1 permits the deductions of debts which become...

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