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BOWERS v. C. I. R.

No. 80-1759.

678 F.2d 509 (1982)

John N. BOWERS and Alma S. Bowers, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided May 26, 1982.

Attorney(s) appearing for the Case

John N. Bowers and Alma S. Bowers, pro se.

Christina Burkholder, W. Jerold Cohen, Chief Counsel, I. R. S., M. Carr Ferguson, Asst. Atty. Gen., Tax Div., U. S. Dept. of Justice, Washington, D. C., for appellee.

Before HAYNSWORTH, Senior Circuit Judge, and BUTZNER and RUSSELL, Circuit Judges.

PER CURIAM:

The Commissioner assessed a deficiency based upon the disallowance of a claimed business bad debt deduction. The Tax Court upheld the Commissioner, but, since it did not address the taxpayer's contentions, we vacate the decision of the Tax Court and remand the case to it for further consideration.

The taxpayer, Bowers,1 was the sole stockholder of a corporation engaged in the...

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