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ELY v. COMMISSIONER

Docket No. 60483.

17 T.C.M. 422 (1958)

T.C. Memo. 1958-86

Robert T. Ely and Jeanne M. Ely v. Commissioner.

United States Tax Court.

Filed May 13, 1958.

Attorney(s) appearing for the Case

William Braham Washabaugh, Jr., Esq., and Enoch C. Filer, Esq., Ariel Building, Erie, Pa., for the petitioners. Donald W. Howser, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency in income tax of $8,057.74 and additions to tax of $717.23 under section 294(d)(1)(A) and $478.16 under section 294(d)(2) for the year 1950.

The questions for decision are (1) whether a deduction of $36,945.36 was properly claimed as a partially worthless business bad debt under section 23(k)(1) of the Internal Revenue Code of 1939, and (2) the propriety...

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