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ESTATE OF BOUNDS v. COMMISSIONER

Docket No. 3551-81.

46 T.C.M. 1209 (1983)

T.C. Memo. 1983-526

Estate of W. Eugene Bounds, deceased, Jane T. Bounds and John B. Long, II, co-personal representatives, and Jane T. Bounds v. Commissioner.

United States Tax Court.

Filed August 25, 1983.

Attorney(s) appearing for the Case

Joshua W. Miles, 9 W. Mulberry St., Baltimore, Md., for the petitioners. John F. Dean, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By statutory notice dated February 5, 1980, respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1974 in the amount of $139,265.05. The issues for decision are (1) whether five loans made by the decedent W. Eugene Bounds to Winter Place Farm, Inc. were business debts, (2) and if so, whether the loans became worthless during 1977, and (3) whether, in the alternative...

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