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READ v. COMMISSIONER

Docket No. 21250-94.

73 T.C.M. 3000 (1997)

T.C. Memo. 1997-262

Robert A. Read v. Commissioner.

United States Tax Court.

Filed June 11, 1997.

Attorney(s) appearing for the Case

LeRoy Boyer, Oklahoma City, Okla., for the petitioner. Donald E. Edwards and Bruce K. Meneely, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a $173,098 deficiency in petitioner's 1984 Federal income tax.

The issues in this case arise out of a claimed net operating loss (NOL) carryback from 1986 to 1984. The NOL carryback is based on a bad debt deduction claimed by petitioner on his 1986 individual Federal income tax return. Petitioner's 1986 bad debt deduction is based upon the alleged worthlessness of his right...

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