WISCONSIN SECURITIES CO. OF DELAWARE v. COMMISSIONER

Docket No. 83946.

21 T.C.M. 588 (1962)

T.C. Memo. 1962-107

Wisconsin Securities Company of Delaware v. Commissioner.

United States Tax Court.

Filed May 2, 1962.


Attorney(s) appearing for the Case

George M. Chester, Esq., 735 N. Water St., Milwaukee, Wis., and James P. Brody, Esq., for the petitioner. Julian R. Ettelson, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined deficiencies in the petitioner's income tax for the years 1955, 1956 and 1957 in the respective amounts of $8,468.75, $4,991.22 and $30,872.36. The issue is whether petitioner is entitled to a business bad debt deduction in 1957 due to the worthlessness of a purported loan of $50,000 (plus accrued but unpaid interest of $3,500) made by it to The Pusey and Jones Corporation...

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