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JOHN v. COMMISSIONER

Docket No. 11603-91.

64 T.C.M. 435 (1992)

T.C. Memo. 1992-452

John C. and Ruth Anne Kelly v. Commissioner.

United States Tax Court.

Filed August 10, 1992.

Attorney(s) appearing for the Case

Brian C. Kelly, One E. Liberty St., Reno, Nev., for the petitioners.

Fred Green, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a $12,913 deficiency in petitioners' Federal income tax for 1984.

At issue is whether petitioners are entitled to a bad debt deduction pursuant to section 16611 in the amount of $94,403 for 1984.

Findings of Fact

Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated...

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