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EGAN v. COMMISSIONER

Docket No. 4568-04.

90 T.C.M. 365 (2005)

T.C. Memo. 2005-234

William A. Egan v. Commissioner.

United States Tax Court.

October 5, 2005.

Attorney(s) appearing for the Case

Peter B. Tiede, for petitioner.

Allison O. Woodbury, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined a $30,618 deficiency in petitioner's Federal income tax for 1998 and that petitioner was liable for a $5,789 accuracy-related penalty for substantial understatement under section 6662(a).1 After concessions,2 we are asked to decide whether petitioner is entitled to deduct $158,381 as a business bad debt in 1998 under section...

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