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HINES v. COMMISSIONER

Docket No. 1504-78.

44 T.C.M. 1345 (1982)

T.C. Memo. 1982-589

William C. Hines v. Commissioner.

United States Tax Court.

Filed October 6, 1982.

Attorney(s) appearing for the Case

Janice P. Noland, for the petitioner. Roberta P. Cona, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency of $150,059.12 in petitioner's 1971 Federal income tax and additions to tax under sections 6651(a)1 and 6653(a) of $36,710.58 and $7,502.95, respectively. After concessions, the remaining issues are (1) whether petitioner is entitled to bad debt deductions on the basis of certain transactions, and (2) whether petitioner is liable for additions...

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