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HOUGH v. COMMISSIONER

Docket No. 22200-82.

51 T.C.M. 1141 (1986)

T.C. Memo. 1986-229

John W. Hough and Louise C. Hough v. Commissioner.

United States Tax Court.

Filed June 5, 1986.

Attorney(s) appearing for the Case

John W. Hough, for the petitioners. Vikki L. Pryor, for the respondent.

Memorandum Opinion

KÖRNER, Judge:

Respondent determined a deficiency of income tax against petitioners with respect to their calendar year 1977 in the amount of $33,568.68. The sole issue presented for our determination is whether a loss suffered by petitioner John W. Hough in 1977, on account of the worthlessness in that year of a bad debt, should be treated as a fully deductible business bad debt under the provisions of section 166(a),

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