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DUNMIRE v. COMMISSIONER

Docket No. 9972-79.

42 T.C.M. 438 (1981)

T.C. Memo. 1981-372

Paul L. Dunmire and Esther Dunmire v. Commissioner.

United States Tax Court.

Filed July 20, 1981.

Attorney(s) appearing for the Case

Michael E. Hoover, Kittanning, Pa., for the petitioners. Edward F. Peduzzi, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the calender year 1976 in the amount of $7,225.

At issue are (1) whether advances made by petitioners to Euwer's, Inc., a family-owned corporation, constitute debt within the meaning of section 166;1 and, if not, (2) whether the advances constitute trade or business expenses deductible under...

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