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RINGGER v. COMMISSIONER

Docket No. 30367-89.

62 T.C.M. 1436 (1991)

T.C. Memo. 1991-613

Peter K. Ringger and Kathleen Ringger v. Commissioner.

United States Tax Court.

Filed December 10, 1991.

Attorney(s) appearing for the Case

Brent R. Armstrong, 175 S. West Temple, Salt Lake City, Utah, for the petitioners. S. Mark Barns, for the respondent.

Memorandum Findings of Fact and Opinion

KÖRNER, Judge:

Respondent determined a deficiency of $12,226.40 in petitioners' 1983 Federal income tax. Following concessions by respondent,1 the issues for decision are: (1) Whether respondent erred in determining that a partnership in which petitioner husband held a 50-percent interest was not entitled to a business bad debt pursuant to section 166(a);2

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