KESSEL v. COMMISSIONER

Docket No. 5323-68.

29 T.C.M. 1171 (1970)

T.C. Memo. 1970-266

John Kessel and Myrtle Kessel v. Commissioner.

United States Tax Court.

Filed September 21, 1970.


Attorney(s) appearing for the Case

Wareham C. Seaman and William F. Roberts, 2318 K St., Sacramento, Calif., for the petitioners. Nicholas G. Stucky, for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $4,022.68 in petitioners' Federal income tax for the calendar year 1966. The only issue presented is whether petitioners' compromise settlement of a $45,557.22 debt for $30,000 entitles them to a deduction in 1966 for a wholly or partially worthless bad debt under section 166(a), I. R. C. 1954.

Findings of Fact

The parties have stipulated certain facts which are...

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