SMITH v. COMMISSIONER

Docket No. 3342-69.

55 T.C. 260 (1970)

ODDEE SMITH AND MABLE B. SMITH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 3, 1970.


Attorney(s) appearing for the Case

Lauch M. Magruder, Jr., and Charles L. Brocato, for the petitioners.

Robert G. Faircloth, for the respondent.


DRENNEN, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1965 and 1966 in the amounts of $43,420.24 and $30,026.03, respectively.

Because of concessions by the parties the only issue presented for our decision is whether certain advances made by petitioner to Smith Petroleum Service, Inc., are deductible as business bad debts, as nonbusiness bad debts, or as ordinary and necessary business expenses. The...

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