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FRANK v. COMMISSIONER

Docket No. 4951-63.

24 T.C.M. 979 (1965)

T.C. Memo. 1965-187

Melville D. Frank and Augusta Frank v. Commissioner.

United States Tax Court.

Filed July 9, 1965.

Attorney(s) appearing for the Case

I. Charles Rhoads, 150 E. Broad St., Columbus, Ohio, for the petitioners. Richard M. Schwartz, for the respondent.

Memorandum Opinion

DAWSON, Judge:

Respondent determined a deficiency in the income tax of petitioners for the year 1961 in the amount of $2,078.48 and additions to tax under sections 6651(a) and 6654, Internal Revenue Code of 1954, in the respective amounts of $103.92 and $88.64.

The issues for decision are: (1) Whether the petitioner Melville D. Frank is entitled to deduct as a business bad debt under section 166(a)(1), Internal Revenue Code of...

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