RILEY v. COMMISSIONER

Docket No. 78776.

20 T.C.M. 41 (1961)

T.C. Memo. 1961-10

John T. Riley and Ruth W. Riley, Husband and Wife v. Commissioner.

United States Tax Court.

Filed January 23, 1961.


Attorney(s) appearing for the Case

Isador Deckelman, Esq., Fidelity Building, Baltimore, Md., for the petitioners. Herbert A. Seidman, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in petitioners' income taxes for the years 1954, 1955, and 1956 in the respective amounts of $5,800.52, $1,898.60, and $3,703.58.

The deficiencies here in issue arise by reason of respondent's disallowance of a deduction claimed by petitioner in 1956 on account of a business bad debt in its full amount of $73,990.06 resulting in a business profit instead of loss for that year, and...

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