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ESTATE OF SHAPIRO v. COMMISSIONER

Docket No. 21705-81.

53 T.C.M. 317 (1987)

T.C. Memo. 1987-126

Estate of Morris W. Shapiro, deceased, Jeanne A. Shapiro and Samuel Shapiro, personal representatives and Jeanne A. Shapiro v. Commissioner.

United States Tax Court.

Filed March 10, 1987.

Attorney(s) appearing for the Case

Edward DeFranceschi, for the petitioners. Mae J. Lew, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $5,165.28 in the petitioners' Federal income tax for 1976 and an addition to tax of $258.26 under section 6653(a) of the Internal Revenue Code of 1954.1 The issues for decision are: (1) Whether the petitioners received income in 1976 when an account receivable due from them was written off as uncollectible; and (2) whether the...

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