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McCRACKIN v. COMMISSIONER

Docket No. 30049-81.

48 T.C.M. 248 (1984)

T.C. Memo. 1984-293

Benjamin H. McCrackin, Jr. and Clara P. McCrackin v. Commissioner.

United States Tax Court.

Filed June 4, 1984.

Attorney(s) appearing for the Case

Nicholas Bouler, for the petitioners. Frank Simmons, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined that there are deficiencies in income tax due from petitioners as follows:

  Year            Deficiency

  1975 ........   $7,067.87
  1976 ........    3,528.50
  1978 ........    4,165.00

The issues are (1) whether certain losses sustained by petitioners constituted business or nonbusiness bad debts; and (2) whether a certain legal fee paid by the petitioners...

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