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CHARLES W. WILLIAMS CONTRACTING COMPANY, INC. v. COMMISSIONER

Docket No. 5659-64.

25 T.C.M. 500 (1966)

T.C. Memo. 1966-93

Charles W. Williams Contracting Company, Inc. v. Commissioner.

United States Tax Court.

Filed April 29, 1966.

Attorney(s) appearing for the Case

Edward A. Johnston, 301 N. Charles St., Baltimore, Md., for the petitioner. Robert E. Garfield and David T. Link, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in petitioner's income tax for the taxable year ended February 28, 1962, in the amount of $44,265.84. The only issue for decision is whether advances of funds by petitioner to Charles W. Williams & Associates, Inc., were loans so as to permit petitioner to deduct the amount of $106,500 as a bad debt, or whether such advances should be treated as capital contributions...

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