PROESEL v. COMMISSIONER

Docket Nos. 5995-76, 6062-76.

77 T.C. 992 (1981)

JAMES V. PROESEL AND ROSEMARY K. PROESEL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 29, 1981.


Attorney(s) appearing for the Case

Calvin Eisenberg, Randall G. Dick, Alan F. Segal, Robert D. Zimelis, Burton W. Kanter, and Donald A. Statland, for the petitioners.

James F. Kidd and Janet A. Engel, for the respondent.


SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $21,661.84 for 1971 and $6,237.09 for 1972. After concessions by the petitioners, the sole issue for decision is whether the petitioners are entitled to either a business loss or a bad debt deduction in 1972 with respect to Mr. Proesel's interest in a motion picture production service partnership.

FINDINGS OF FACT

Some of the facts have been...

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