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CAPPS v. COMMISSIONER

Docket No. 39282.

14 T.C.M. 505 (1955)

T.C. Memo. 1955-136

C. W. Capps and Margaret G. Capps v. Commissioner.

United States Tax Court.

Filed May 25, 1955.

Attorney(s) appearing for the Case

Ben F. Mitchel, Esq., and Percy C. Young, Esq., for the petitioners. Lester R. Uretz, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined a deficiency for 1949 in the amount of $3,241.24. The deficiency results from the respondent's disallowance of a loss deduction in the amount of $17,500. The chief question to be decided is whether petitioner is entitled to a loss deduction under section 23(e) of the 1939 Code in the amount of $17,500, as the result of his performance of a guarantee agreement.

Findings...

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