BARNARD v. COMMISSIONER

Docket No. 1131-62.

22 T.C.M. 1773 (1963)

T.C. Memo. 1963-338

Robert L. Barnard v. Commissioner.

United States Tax Court.

Filed December 27, 1963.


Attorney(s) appearing for the Case

Benjamin Becker, for the petitioner. Frederic S. Kramer, for the respondent.


Memorandum Findings of Fact and Opinion

OPPER, Judge:

A deficiency in 1959 income tax of $220 has been determined. The issue is whether cash advances made by petitioner (1) constituted an allowable nonbusiness bad debt under section 166(d), I .R. C. 1954, or, if not, (2) constituted a deductible loss under section 165(c), I. R. C. 1954.

Findings of Fact

Petitioner Robert L. Barnard (hereinafter referred to as petitioner) is an individual...

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