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SMITH v. COMMISSIONER

Docket No. 9354-72.

62 T.C. 263 (1974)

EARL M. SMITH AND RUTH A. SMITH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 30, 1974.

Attorney(s) appearing for the Case

H. Vernon Davids, for the petitioners.

Robert P. Edler, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency of $8,886.37 in petitioners' Federal income tax for 1967. The issue for decision is whether petitioners are entitled to a business bad debt deduction, as permitted by section 166(a),1 for a loss incurred on loans to their wholly owned corporation, or whether they are limited by section 166(d) to a nonbusiness bad debt deduction for their loss.

FINDINGS OF FACT

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