CONSTANTIN v. COMMISSIONER

Docket No. 95445.

25 T.C.M. 166 (1966)

T.C. Memo. 1966-27

E. Constantin, Jr. and Ruth F. Constantin v. Commissioner.

United States Tax Court.

Filed January 31, 1966.


Attorney(s) appearing for the Case

Jack Gray Johnson, 1700 Mercantile Bank Bldg., Dallas, Tex., and Robert L. Blumenthal, for the petitioners. James F. Hart, for the respondent.


Memorandum Findings of Fact and Opinion

HOYT, Judge:

Respondent determined a deficiency in the income tax of petitioners for the taxable year 1958 in the amount of $62,551.77. The only issue presented is whether petitioners are entitled to a business bad debt deduction in the amount of $117,184.47 for the taxable year 1958, or in the alternative, to a nonbusiness bad debt deduction for that year.

Findings of Fact

Some of the facts have...

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