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BOWERS v. C.I.R.

No. 83-1082.

716 F.2d 1047 (1983)

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

United States Court of Appeals, Fourth Circuit.

Decided August 31, 1983.

Attorney(s) appearing for the Case

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

Kenneth W. Gideon, Chief Counsel, Christina Burkholder, Chief Counsel, N. Jerold Cohen, Chief Counsel Internal Revenue Service; M. Carr Ferguson, Asst. Atty. Gen., Tax Division, Dept. of Justice, Washington, D.C., for appellee.

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

PER CURIAM:

This case arose when the Commissioner of Internal Revenue disallowed a business bad debt deduction claimed by the taxpayer, Bowers. The Tax Court upheld the Commissioner's disallowance on the grounds that Bowers was not in the trade or business of lending money and he did not show the loan was proximately related to his trade or business. On appeal, we agreed the worthless loan could not be deducted as a business bad debt on either of these theories, but...

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