HARDEE v. COMMISSIONER

Docket No. 1567-73.

34 T.C.M. 608 (1975)

T.C. Memo. 1975-129

W.L. Hardee and Elnora Hardee v. Commissioner.

United States Tax Court.

Filed May 7, 1975.


Attorney(s) appearing for the Case

Thomas C. O'Bannon, 818 Barnett Bk. Bldg., Jacksonville, Fla., for the petitioners. Donald W. Williamson, Jr., for the respondent.


Memorandum Opinion

TIETJENS, Judge:

The Commissioner determined deficiencies of $7,773.12, $8,805.31, and $8,911.84 in the Federal income taxes of petitioners for their taxable years 1968, 1969, and 1970, respectively.

Petitioners have made certain concessions so that the only question remaining for decision is whether certain payments made in connection with the obligation of W.L. Hardee (hereafter petitioner) as guarantor can be deducted as losses...

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