CRABTREE, J.T.C.
Plaintiff seeks review of a deficiency in gross income tax determined by defendant for taxable year 1987. The amount of the deficiency is $43,867.43, plus interest. The deficiency arises from defendant's disallowance of nonbusiness bad debt losses amounting to $995,557 deducted on plaintiff's 1987 gross income tax return. In his complaint plaintiff increased his claimed loss on one transaction from $742,202 to $1 million. This particular loss, plaintiff...
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