No. 20897.

376 F.2d 623 (1967)

Leonard LUNDGREN and Evelyn Lundgren, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals Ninth Circuit.

April 14, 1967.

Attorney(s) appearing for the Case

William H. Kinsey, Mautz, Souther, Spaulding, Kinsey & Williamson, Portland, Or., for appellant.

Mitchell Rogovin, Asst. Atty. Gen., Lester R. Uretz, Chief Counsel, Gilbert Andrews, Atty., Tax Div., Dept. of Justice, Lee A. Jackson, David O. Walter, Robert I. Waxman, Washington, D. C., for appellee.

Before CHAMBERS, Circuit Judge, MADDEN, Judge of the United States Court of Claims, and BROWNING, Circuit Judge.

MADDEN, Judge:

This is an appeal from a decision of the Tax Court affirming a determination of the Commissioner of Internal Revenue which denied a deduction claimed as a business bad debt under section 166 of the Internal Revenue Code of 1954. Leonard Lundgren (hereinafter referred to as petitioner) and Evelyn R. Lundgren are husband and wife. Evelyn is a party to the proceedings only because the Lundgrens filed a joint income tax return for the year involved.


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