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SAIA v. COMMISSIONER

Docket No. 301-73.

33 T.C.M. 1391 (1974)

T.C. Memo. 1974-301

Frank J. Saia and Grace P. Saia v. Commissioner.

United States Tax Court.

Filed December 4, 1974.

Attorney(s) appearing for the Case

Theodore L. Jones, P.O. Box 2706, Baton Rouge, La., for the petitioners. Paul H. Waldman, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

The respondent determined a deficiency in petitioners' federal income tax for the taxable year 1970 in the amount of $67,625.49. This deficiency resulted from respondent's disallowance of three business bad debts and a "compensation for services" expense claimed by petitioners as employee business expenses on their individual tax return for 1970.

Respondent determined that these debts were...

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