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SIGGELKOW v. COMMISSIONER

Docket No. 2550-97.

77 T.C.M. 1403 (1999)

T.C. Memo. 1999-44

Larry J. and Angela L. Siggelkow v. Commissioner.

United States Tax Court.

Filed February 10, 1999.

Attorney(s) appearing for the Case

R. Glen Woods, for the petitioners. Wendy S. Harris, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a deficiency in petitioners' 1992 Federal income tax in the amount of $24,993. The issue for our consideration is whether petitioners are entitled to take an ordinary loss deduction for a business bad debt as allowed by section 166.1 Petitioners contend that, in the ordinary course of Mr. Siggelkow's business, he made a bona fide loan to a company he...

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