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ROSE v. COMMISSIONER

Docket No. 22004-83.

52 T.C.M. 1346 (1987)

T.C. Memo. 1987-19

Allan V. Rose and Christina Rose v. Commissioner.

United States Tax Court.

Filed January 12, 1987.

Attorney(s) appearing for the Case

Vicki G. Cheikes, 18 Lydia Lane, Garden City, N.Y., for the petitioners. Arnold T. Gould, for the respondent.

Memorandum Opinion

WILLIAMS, Judge:

This matter is before the Court on cross-motions for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1978 in the amount of $14,246.00. The issue for our decision is whether petitioners are entitled to deduct a worthless debt pursuant to section 166.1 The...

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