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SMITH v. COMMISSIONER

Docket No. 3082-78.

48 T.C.M. 517 (1984)

T.C. Memo. 1984-361

Hinsdale Smith, Jr. and Marjorie L. Smith v. Commissioner.

United States Tax Court.

Filed July 16, 1984.

Attorney(s) appearing for the Case

Hinsdale Smith, Jr., pro se. Thomas C. Boscarino, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency of $6,426 in petitioners' 1974 Federal income tax. After concessions, the sole issue for decision is whether a loss sustained by petitioner during 1974 in the amount of $16,320, which he had loaned to his wholly-owned corporation, constitutes a business or a nonbusiness bad debt loss deduction under section 166.1

Findings of Fact...

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