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GROSS v. C. I. R.

No. 22023.

401 F.2d 600 (1968)

Rudolph L. GROSS and Catherine D. Gross, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

October 7, 1968.

Attorney(s) appearing for the Case

Dean M. Alexander (argued), Portland, Or., for appellant.

Chester C. Davenport, Jr. (argued), Washington, D. C., Mitchell Rogovin, Asst. Atty. Gen., Tax Div., Lee A. Jackson, Grant Wiprud, Dept. of Justice, Washington, D. C., for appellee.

Before BARNES and MERRILL, Circuit Judges, and McNICHOLS, District Judge.

BARNES, Circuit Judge:

This is a petition for review of a tax court decision that taxpayers' losses from non-repayment of loans were not proximately related to any trade or business conducted by taxpayers as individuals, and hence were not fully deductible as business bad debts but were qualified, in a limited manner, as nonbusiness bad debts (See 166 Internal Revenue Code of 1954)1 and Treasury Regulations

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