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BERNSTEIN v. COMMISSIONER

Docket No. 76315.

19 T.C.M. 1187 (1960)

T.C. Memo. 1960-213

Arthur Bernstein and Grace Bernstein v. Commissioner.

United States Tax Court.

Filed October 7, 1960.

Attorney(s) appearing for the Case

Joseph M. Nolan, Esq., 60 Park Place, Newark, N. J., for the petitioners. Arthur Pelikow, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner determined a deficiency in income tax for the taxable year 1955 in the amount of $4,186.62. The question for decision is whether a loss sustained in 1955 was a loss from a business bad debt under section 166(a)(1), 1954 Code, or a loss from a nonbusiness bad debt within section 166(d)(2).

Findings of Fact

The stipulated facts are found as stipulated.

The petitioners...

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