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SEKULOW v. COMMISSIONER

Docekt No. 7836-78

41 T.C.M. 582 (1980)

T.C. Memo. 1980-564

Abraham Sekulow and Florence Sekulow v. Commissioner.

United States Tax Court.

Filed December 17, 1980.

Attorney(s) appearing for the Case

David R. Cohan, 1230 Sun Life Bldg., Baltimore, Md., for the petitioners. John F. Dean, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency in the amount of $5,008 in petitioners' Federal income taxes for 1974. The issues for decision are: (1) whether petitioners advanced sums to a corporation; (2) whether such sums represented bona fide loans or contributions to the corporation's capital; (3) to the extent the funds advanced to the corporation are considered loans, did they constitute business bad debts...

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