HERITAGE v. COMMISSIONER

Docket No. 78491.

20 T.C.M. 321 (1961)

T.C. Memo. 1961-62

Joseph J. Heritage and Beth Cross Heritage v. Commissioner.

United States Tax Court.

Filed February 28, 1961.


Attorney(s) appearing for the Case

Milton S. Applebaum, Esq., 38 S. Dearborn St., Chicago, Ill., for the petitioners. Jay B. Kelly, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

The respondent determined deficiencies in income tax of petitioners in the amounts of $367.40, $276.94, and $382.63 for the calendar years 1954, 1955, and 1956, respectively.

The sole question for decision is whether petitioners are entitled to a deduction either as an ordinary and necessary business expense, a loss incurred in trade or business, or a business bad debt of amounts paid on a prior...

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