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REECE v. COMMISSIONER

Docket No. 2955-74.

36 T.C.M. 299 (1977)

T.C. Memo. 1977-69

James A. Reece and Gladys W. Reece v. Commissioner.

United States Tax Court.

Filed March 16, 1977.

Attorney(s) appearing for the Case

Harlan Dodson, III, 900 Nashville Trust Bldg., Nashville, Tenn. for the petitioners. William Robert Pope, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

    1969 ............... $27,158.57
    1970 ............... $ 4,079.91

The issue for decision is whether petitioners' unrepaid advances of funds to a wholly owned corporation, R & W Food Services, Inc., should be classified as business bad debts under section 166(a),

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