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MARSHALL v. COMMISSIONER

Docket No. 78898.

19 T.C.M. 1577 (1960)

T.C. Memo. 1960-288

Robert D. Marshall and Helen B. Marshall v. Commissioner.

United States Tax Court.

Filed December 30, 1960.

Attorney(s) appearing for the Case

Charles Blair, Esq., for the petitioner. Seymour I. Sherman, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

The respondent determined a deficiency in the income tax of petitioners in the amount of $13,900.53 for the taxable year 1954. The sole issue for decision is whether petitioners are entitled to a deduction of $50,200 as a nonbusiness bad debt. The Commissioner, in disallowing this deduction, stated in the notice of deficiency:

It is held that worthlessness of advances of $50,200.00 to Tech-Mulsion...

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