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BERNER v. COMMISSIONER

Docket Nos. 78937 and 84191.

20 T.C.M. 107 (1961)

T.C. Memo. 1961-23

Milford C. Berner and Ruth M. Berner v. Commissioner.

United States Tax Court.

Filed January 31, 1961.

Attorney(s) appearing for the Case

Milford C. Berner, pro se, 240 Winwood Dr., Lake Forest, Ill. Nelson E. Shafer, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

The Commissioner determined deficiencies in petitioners' income tax for the calendar years 1955 and 1957 in the amounts of $504.21 and $266.83, respectively. The issues for decision are: (1) Whether the Commissioner is correct in considering the amount of $2,350 deducted in full by petitioner in 1955 as a loan to a corporation which had become insolvent to be a nonbusiness bad debt; (2) whether respondent...

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