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KADLEC v. COMMISSIONER

Docket No. 22506-94.

71 T.C.M. 2399 (1996)

T.C. Memo. 1996-119

Charles Kadlec and Lesley C. Kadlec v. Commissioner.

United States Tax Court.

Filed March 12, 1996.

Attorney(s) appearing for the Case

Lisa J. Steele, for the petitioners. Melanie M. Garger, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge:

Respondent determined a deficiency of $50,115 in petitioners' 1988 Federal income tax. Respondent further determined an addition to tax pursuant to section 6651(a)(1)1 in the amount of $12,529.

After concessions,2 the sole issue remaining for decision is whether petitioners are entitled to a bad debt deduction of $182,451.03 for the 1988...

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