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ESTATE OF BESAG v. COMMISSIONER

Docket No. 1907-72.

34 T.C.M. 737 (1975)

T.C. Memo. 1975-163

Estate of Lucie Besag, Crocker National Bank, a National Banking Association, and Leon J. Alexander, co-executors v. Commissioner.

United States Tax Court.

Filed May 28, 1975.

Attorney(s) appearing for the Case

Gene R. Prasse, Third Fl. 9720 Wilshire Blvd., Beverly Hills, Calif., for the petitioners. Richard H. Gannon, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $28,286 in the income tax of petitioners' decedent for the year 1967. The only remaining issue is whether certain loans made by decedent became uncollectible during 1967, giving rise to a nonbusiness bad debt loss under section 166(d).1

All of the evidentiary facts have been stipulated. The stipulation of facts and attached exhibits are incorporated...

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