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SCHUSTER v. COMMISSIONER

Docket No. 796-65.

50 T.C. 98 (1968)

MAX SCHUSTER AND ELSE SCHUSTER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 17, 1968.

Attorney(s) appearing for the Case

Leo Sussman, for the petitioners.

William T. Hayes, for the respondent.

OPINION

RAUM, Judge:

The Commissioner determined a deficiency in petitioners' income tax for the year ended December 31, 1961, in the amount of $7,337.36. Petitioners have agreed to most of the Commissioner's adjustments, and dispute here only the Commissioner's actions with respect to the reserve for bad debts account of a sole proprietorship once operated by petitioner Max Schuster. The entire business of the proprietorship, including its accounts...

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