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SAFIR v. COMMISSIONER

Docket No. 8375-78.

43 T.C.M. 757 (1982)

T.C. Memo. 1982-123

Marshall P. Safir and Gladys Safir v. Commissioner.

United States Tax Court.

Filed March 15, 1982.

Attorney(s) appearing for the Case

Marshall P. Safir, pro se, Great Neck, N.Y. Laurence D. Ziegler, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the year 1974 in the amount of $11,300. After a concession,1 the only issue for decision is whether petitioners are entitled to bad debt deduction under section 166 or a loss deduction under section 165.2

Findings of Fact

Some of the facts have been stipulated...

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