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WALTER v. COMMISSIONER

Docket No. 11519-94.

71 T.C.M. 2871 (1996)

T.C. Memo. 1996-200

Frank A. Walter and Joann R. Walter v. Commissioner.

United States Tax Court.

Filed April 24, 1996.

Attorney(s) appearing for the Case

Frank A. Walter, pro se. Gerald W. Douglas, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1991 in the amount of $10,902.

The sole issue for decision is whether petitioners are entitled for 1991 to a nonbusiness bad debt deduction under section 166(d)(1)(B)1 for punitive damages that were awarded to, but not collected by, petitioner Frank A. Walter during that year?

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