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ESTATE OF RAPOPORT v. COMMISSIONER

Docket No. 2754-79.

44 T.C.M. 1330 (1982)

T.C. Memo. 1982-584

Estate of Herbert M. Rapoport, Deceased, Kathryn Rapoport, Special Administrator, and Kathryn Rapoport v. Commissioner.

United States Tax Court.

Filed October 4, 1982.

Attorney(s) appearing for the Case

R. David Garber, 554 Continental Bldg., Omaha, Neb., for the petitioners. J. Anthony Hoefer, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the years 1974 and 1975 in the amounts of $2,371.43 and $4,375.51, respectively. The issues for decision are whether there was a bad debt and, if so, whether it was a business or nonbusiness bad debt.

Findings of Fact

The facts of this case have been fully stipulated and are so found. The stipulation of facts...

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