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FITCH v. COMMISSIONER

Docket No. 71641.

19 T.C.M. 1491 (1960)

T.C. Memo. 1960-268

Grant D. Fitch and Marguerite Fitch v. Commissioner.

United States Tax Court.

Filed December 13, 1960.

Attorney(s) appearing for the Case

Hubert L. Will, Esq., for the petitioners. Charles B. Wolfe, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency of $2,668.20 in petitioners' income tax for the year 1954. The sole issue is whether the losses suffered by Grant D. Fitch in the amount of $6,625 on two loans to Frank Abbate constitute business or nonbusiness bad debts.

Findings of Fact

Some of the facts have been stipulated and are so found...

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