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ADAMO v. COMMISSIONER

Docket No. 44882.

13 T.C.M. 951 (1954)

T. C. Memo. 1954-171

Frank S. H. Adamo v. Commissioner.

United States Tax Court.

Filed October 12, 1954.

Attorney(s) appearing for the Case

Saul I. Radin, Esq., 37 Wall Street, New York, N. Y., for the petitioner. Charles M. Greenspan, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $3,340.71 in the income tax of the petitioner for 1947. The only issue for decision is whether the Commissioner erred in holding that the amount of $11,670.27, claimed as a bad debt of 1947, was a nonbusiness bad debt within the meaning of section 23(k)(4) of the Internal Revenue Code of 1939 to be taken into account as a short-term...

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