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JOHN v. COMMISSIONER

Docket No. 10604-02.

88 T.C.M. 437 (2004)

T.C. Memo. 2004-257

Maurice E. John, Jr. and Jan E. John v. Commissioner.

United States Tax Court.

November 9, 2004.

Attorney(s) appearing for the Case

R. Thomas Blackburn, Jr., for petitioners.

Mark D. Eblen, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge.

Respondent determined a deficiency of $179,403 in petitioners' Federal income taxes for 1995. The issue to be decided is whether petitioners are entitled to deduct $491,054 as a business bad debt deduction under section 1661 in 1995. We hold they are not.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of facts and...

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