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WALSH v. C. I. R.

No. 8671.

313 F.2d 389 (1963)

John E. WALSH, Jr., and Anna D. Walsh, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided January 15, 1963.

Attorney(s) appearing for the Case

Patrick J. Head, Washington, D. C. (John L. Ingoldsby, Jr., Washington, D. C., on brief), for petitioners.

Ralph A. Muoio, Atty., Dept. of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks and L. W. Post, Attys., Dept. of Justice, on brief), for respondent.

Before HAYNSWORTH and BRYAN, Circuit Judges, and LEWIS, District Judge.

LEWIS, District Judge.

The Tax Court of the United States, in the unreported consolidated cases of John E. Walsh, Jr. and Anna D. Walsh versus Commissioner of Internal Revenue, Docket Nos. 85544 and 86978, held that advances totaling $24,082.18, made by the taxpayer to his son's corporation in 1953, 1954 and 1955, constituted nonbusiness debts and were not fully deductible as such when they became worthless in 1956. The Walshes...

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