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PROVOST v. COMMISSIONER

Docket No. 3936-97.

79 T.C.M. 2098 (2000)

T.C. Memo. 2000-177

Edward L. Provost and Vicky L. Provost v. Commissioner.

United States Tax Court.

Filed May 26, 2000.

Attorney(s) appearing for the Case

Terrence J. Moore, for the petitioners. Lisa N. Primavera, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency in petitioners' 1993 Federal income tax of $68,083 and an accuracy-related penalty of $13,617 under section 6662(a).1

The issues for decision are: (1) Whether petitioners' advance of $200,000 to Richard Magness is deductible as a business bad debt under section 166 and (2) whether petitioners are liable for an accuracy-related penalty...

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