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ESTATE OF STOKES v. COMMISSIONER

Docket No. 30016.

10 T.C.M. 1111 (1951)

Estate of J. Stogdell Stokes, deceased, Provident Trust Company of Philadelphia, May Margaret Stokes, John S. Stokes, Jr., D. Robert Yarnall, Philip Price, and Percy C. Madeira, Jr., Executors v. Commissioner.

United States Tax Court.

Entered November 21, 1951.

Attorney(s) appearing for the Case

Logan Morris, Esq., for the petitioners. Stanley W. Herzfeld, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The respondent determined a deficiency in the income tax return of J. Stogdell Stokes, deceased, for the taxable year January 1, to September 26, 1947, in the amount of $8,096.21. The sole issue to be decided is whether the amount of $14,627.48 is deductible in full as a business bad debt under section 23 (k)(1) or is a non-business bad debt under section 23 (k)(4) which should...

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