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DOERFLER v. COMMISSIONER

Docket No. 10859-75.

36 T.C.M. 789 (1977)

T.C. Memo. 1977-193

Lawrence J. Doerfler and Norma L. Doerfler v. Commissioner.

United States Tax Court.

Filed June 22, 1977.

Attorney(s) appearing for the Case

Richard F. McDivitt, City Nat. Bk. Tur., Oklahoma City, Okla. and Patrick Jon Casey, for the petitioners. Osmun R. Latrobe, for the respondent.

Memorandum Opinion

TIETJENS, Judge:

Respondent determined the following deficiencies in petitioners' income taxes:

  Year               Deficiency

  1969 ............. $14,730.74
  1970 .............  15,729.03

The issue is whether a loss arising from the satisfaction of a guarantee qualifies as a business bad debt.

The parties have filed a full stipulation of facts which together with the exhibits attached thereto are...

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