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BOWERS v. COMMISSIONER

Docket No. 850-78.

45 T.C.M. 2 (1982)

T.C. Memo. 1982-635

John N. Bowers and Alma S. Bowers v. Commissioner.

United States Tax Court.

Filed November 1, 1982.

Attorney(s) appearing for the Case

Ted T. Mercer, specially recognized for the petitioners. Lawrence D. Garr, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

This case is before us on remand from the Fourth Circuit Court of Appeals. In our previous consideration of the issue herein,1 we found that a worthless loan could not be deducted as a business bad debt because petitioner husband, John N. Bowers (hereinafter petitioner), was not in the trade or business of lending money and because...

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