O'NEILL v. COMMISSIONER

Docket No. 9728.

6 T.C.M. 993 (1947)

Thomas J. O'Neill v. Commissioner.

United States Tax Court.

Entered August 27, 1947.


Attorney(s) appearing for the Case

Gustave Simons, Esq., for the petitioner. Clay C. Holmes, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

DISNEY, Judge:

This proceeding involves a deficiency of $16,777.05 in income tax for 1941. The single error in the case is whether the respondent erred in treating certain advances of petitioner to corporations as resulting in long-term capital losses instead of deductible bad debts, as claimed by the petitioner in his return. Facts stipulated at the hearings are embodied in our findings from other evidence.

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