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ESTATE OF SCHMIDT v. COMMISSIONER

Docket No. 2116-63.

42 T.C. 1130 (1964)

ESTATE OF HEINZ SCHMIDT, DECEASED, AND CHARLOTTE SCHMIDT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 30, 1964.

Attorney(s) appearing for the Case

Max Weingarten, for the petitioners.

John O. Hargrove, for the respondent.

Respondent determined a deficiency in income tax for the year ended December 31, 1959, in the amount of $17,251.05.

At issue is whether a balance in the amount of $27,445.711 in a reserve for bad debts account of a proprietorship was includable in petitioners' taxable income in 1959 when in that year the business of the proprietorship, including accounts receivable, was transferred to a corporation in a transaction which qualified under...

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