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SIMON v. COMMISSIONER

Docket No. 3297-74.

37 T.C.M. 1849 (1978)

T.C. Memo. 1978-485

Robert A. and Sandra L. Simon v. Commissioner.

United States Tax Court.

Filed December 6, 1978.

Attorney(s) appearing for the Case

Robert A. Simon, pro se, 29 Riverside Dr., P.O. Box 116, Binghamton, N.Y. William J. Neild, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a $64,898 deficiency in petitioners' 1969 income tax. The sole issue is whether petitioners' loans to three businesses became wholly worthless during 1969.

Findings of Fact

At the time they filed their petition, Robert A. and Sandra L. Simon were residents of Binghamton, New York. Sandra is a party only by virtue of having filed joint returns with her husband. When...

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