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MOONEY v. COMMISSIONER

Docket No. 60544.

17 T.C.M. 631 (1958)

T.C. Memo. 1958-116

Milton A. and Beatrice Mooney v. Commissioner.

United States Tax Court.

Filed June 20, 1958.

Attorney(s) appearing for the Case

Theodore M. Garver, Esq., for the petitioners. L. Robert Leisner, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined a deficiency in income tax for the taxable year 1953 in the amount of $7,355.30 and additions under sections 294(d)(1)(A) and 294(d)(2), 1939 Code, in the total amount of $1,625.23. The principal question is whether a debt in the amount of $14,015 was a nonbusiness bad debt for which deduction is limited by section 23(k)(4), as respondent determined, or was a business bad...

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