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HOLLAND v. C.I.R.

No. 83-1060.

728 F.2d 360 (1984)

Edward J. HOLLAND, Jr., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 29, 1984.

Attorney(s) appearing for the Case

Hallison H. Young, Stanley H. Pitts, Patmon & Young, Carol Evans (argued), Detroit, Mich., for petitioner-appellant.

Kenneth W. Gideon, Chief Counsel, I.R.S., George M. Sellinger, Washington, D.C., Glenn L. Archer, Jr., Michael L. Paup (argued), Tax Div., Dept. of Justice, James F. Miller, Richard Farber, Washington, D.C., for respondent-appellee.

Before MARTIN, CONTIE, and WELLFORD, Circuit Judges.

PER CURIAM.

Taxpayer Edward Holland, Jr. challenges the Tax Court's refusal to allow him a $50,000 business bad debt deduction for a loan that he made to his own company. See Tax Ct. Memo Dec., P.H. ¶ 82,428 (1982).

Holland is a song writer and record producer. At all times relevant to this case, he was also president and sole shareholder of Hot Wax Records, Inc., a corporation formed for the production of musical recordings. First incorporated...

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