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COUCH v. COMMISSIONER

Docket No. 22110-93.

70 T.C.M. 1529 (1995)

T.C. Memo. 1995-583.

Harold T. and Christine B. Couch v. Commissioner.

United States Tax Court.

Filed December 6, 1995.

Attorney(s) appearing for the Case

Joseph D. Anroman, for the petitioners. Carmino J. Santaniello, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined a $10,962 deficiency in petitioners' 1990 income tax plus a section 6662(a)1 penalty in the amount of $2,192. The issues for decision are: (1) Whether a deduction claimed by petitioners as a business bad debt became worthless in 1990, and (2) whether the debt involved qualifies as a "business" bad debt under section 166.2 The case was submitted...

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