AMERICAN CREDIT CORP. v. COMMISSIONER

Docket No. 5339-67.

32 T.C.M. 122 (1973)

T.C. Memo. 1973-33

American Credit Corporation v. Commissioner.

United States Tax Court.

Filed February 13, 1973.


Attorney(s) appearing for the Case

Sidney B. Gambill, 747 Union Trust Bldg., Pittsburgh, Pa., and Carl E. Glock, Jr., for the petitioner. Steve C. Horowitz, for the respondent.


Memorandum Findings of Fact and Opinion

HOYT, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable years ending August 31, 1960, 1962, and 1963, in the amounts of $4,379.42, $364,879.22, and $430,503.59, respectively.

The issues for decision are whether petitioner's predecessor, Home Finance Group, Inc., is entitled to deductions for bad debts under section 166(a)(1) and losses from worthless stock under sections 165...

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