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GOODING v. COMMISSIONER

Docket No. 85694.

20 T.C.M. 1542 (1961)

T.C. Memo. 1961-299

Richard M. Gooding and Marcella M. Gooding, Husband and Wife v. Commissioner.

United States Tax Court.

Filed October 30, 1961.

Attorney(s) appearing for the Case

Joe S. Gullo, Esq., for the petitioners. Charles C. Shaw, Jr., Esq., for the respondent.

Memorandum Opinion

MULRONEY, Judge:

The respondent determined a deficiency in the petitioners' income tax for 1958 in the amount of $221. The deficiency arose from respondent's disallowance of a bad debt deduction in the amount of $1,000 claimed by the petitioners for the year 1958. Petitioners in their pleadings claim there was no deficiency for the year 1958, and, in fact, an overpayment of approximately $351 on their income tax for 1958. However, in the...

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