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DISON v. COMMISSIONER

Docket No. 5619-63.

24 T.C.M. 794 (1965)

T.C. Memo. 1965-150

Ernest E. and Virginia E. Dison v. Commissioner.

United States Tax Court.

Filed June 1, 1965.

Attorney(s) appearing for the Case

Gerard J. O'Brien, for the petitioners. Bernard J. Boyle, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

Respondent determined a deficiency in petitioners' 1959 income tax in the amount of $4,062.84.

The issues are whether certain advances made by petitioner Ernest E. Dison in 1961 to his wholly-owned corporation were contributions to capital or loans, and, if loans, were they deductible as business bad debts in 1961 when later that year the corporation went into bankruptcy?

Findings...

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