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ESTATE OF BLAZZARD v. COMMISSIONER

Docket No. 31002-88.

62 T.C.M. 54 (1991)

T.C. Memo. 1991-296

Estate of Ward W. Blazzard, Deceased, Louella C. Blazzard, Personal Representative, and Louella C. Blazzard v. Commissioner.

United States Tax Court.

Filed July 3, 1991.

Attorney(s) appearing for the Case

Michael M. Thomas, for the petitioners.

James B. Ausenbaugh, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge.

Respondent determined a deficiency of $13,547 in petitioners' 1985 joint Federal income tax liability. After settlement of some issues, the issue for decision relates to the deductibility as a business bad debt of a "100-percent penalty" decedent Ward W. Blazzard paid in 1985 with respect to unpaid employment taxes of a closely held corporation in which decedent had an interest.

Findings of Fact...

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