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HOUGH v. C.I.R.

No. 88-3168.

882 F.2d 1271 (1989)

John W. HOUGH and Louise C. Hough, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 21, 1989.

Attorney(s) appearing for the Case

John W. Hough, Paul D. Weatherhead, Hough, Weatherhead, Kinsella, Chicago, Ill., for petitioners-appellants.

Gary R. Allen, William S. Rose, Jr., Asst. Atty. Gen., David E. Brunori, Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, William F. Nelson, I.R.S., David E. Carmack, Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before COFFEY, EASTERBROOK, and RIPPLE, Circuit Judges.

RIPPLE, Circuit Judge.

Taxpayers John and Louise Hough claimed a business-related bad debt deduction in their 1978 tax return, pursuant to 26 U.S.C. § 166.1 The Commissioner of Internal Revenue (Commissioner) disallowed this deduction and, on August 12, 1985, issued a notice of deficiency. The Houghs filed a petition with the United States Tax Court contesting the deficiency determination and alleging that the Internal Revenue Service...

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