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BURTON v. C. I. R.

No. 76-1037.

549 F.2d 1111 (1977)

Rodney B. BURTON and Patricia L. Burton, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided March 8, 1977.

Attorney(s) appearing for the Case

Stuart Sinai, Dakmak, Gropman & Sinai, P. C., Detroit, Mich., for petitioners-appellants.

Scott P. Cramption, Asst. Atty. Gen., Tax Div., U. S. Dept. of Justice, Gilbert E. Andrews, Elmer J. Kelsey, Robert A. Bernstein, Francis J. Gould, Washington, D. C., for respondent-appellee.

Before CELEBREZZE, LIVELY and ENGEL, Circuit Judges.

PER CURIAM.

The taxpayers appeal from a decision of the United States Tax Court which held that advancements of money by Rodney Burton to a business enterprise in which he had made an investment without participating in the operation or management thereof were not deductible as either a business bad debt under Section 166 of the Internal Revenue Code or as a business expense under Section 162. The memorandum opinion of the Tax Court is reported at 34 T.C.M. 898.<...

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