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SHINEFELD v. COMMISSIONER

Docket No. 2504-73.

65 T.C. 1092 (1976)

DAVID SHINEFELD AND ESTATE OF JEANETTE SHINEFELD, DECEASED, DAVID SHINEFELD, EXECUTOR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 3, 1976.

Attorney(s) appearing for the Case

Leonard Sarner, for the petitioners.

Howard W. Gordon, for the respondent.

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

         Year                                   Deficiency

         1967 ----------------------------      $56,891.00
         1970 ----------------------------       24,456.80

The only issue presented is whether a bad debt loss suffered in 1970 is deductible in full or is subject to the limitations imposed by section...

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