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ASTLEFORD v. C. I. R.

No. 74-1798.

516 F.2d 1394 (1975)

M. G. ASTLEFORD and Jane Z. Astleford, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided May 29, 1975.

Attorney(s) appearing for the Case

Dennis M. Mathisen, Minneapolis, Minn., for appellants.

Michael L. Paup, Atty., Tax Div., U. S. Dept. of Justice, Washington, D. C., for appellee.

Before GIBSON, Chief Judge, STEPHENSON, Circuit Judge, and SMITH, Senior District Judge.

PER CURIAM.

Taxpayers M. G. and J. Z. Astleford have appealed a judgment of the United States Tax Court determining deficiencies in the total amount of $271,006.77 due to disallowance of business bad debt deductions in the tax years 1963, 1964 and 1966 occasioned by a total loss of $609,658.61 sustained by the taxpayers' partnership. The loss was characterized by the court as a capital loss for the reason that the unrecovered advances made by the taxpayers to Melroy...

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