HIGGINS v. COMMISSIONER

Docket No. 8305-74.

35 T.C.M. 962 (1976)

T.C. Memo. 1976-220

Frank A. Higgins and Janie K. Higgins v. Commissioner.

United States Tax Court.

Filed July 13, 1976.


Attorney(s) appearing for the Case

Robert H. Carpenter, for the petitioners. Thomas L. Kummer, for the respondent.


Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a $1,514.85 deficiency in petitioners' Federal income tax for 1971. We are called upon to decide whether petitioners' payments on their guaranty of Frank A. Higgins' corporate client's debt constituted a business or nonbusiness bad debt loss.

Findings of Fact

The stipulation of facts and accompanying exhibits are incorporated herein by this reference.

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