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ADELSON v. UNITED STATES

No. 112-76.

553 F.Supp. 1082 (1982)

Sheldon G. ADELSON and Sandra Adelson v. The UNITED STATES.

United States Claims Court.

December 27, 1982.

Attorney(s) appearing for the Case

Robert S. Lappin, Boston, Mass., attorney of record, for plaintiffs. Barry C. Klickstein and Lappin, Rosen, Goldberg, Slavet, Levenson & Wekstein, Boston, Mass., of counsel.

Ellen C. Specker, Washington, D.C., with whom was Asst. Atty. Gen. Glenn L. Archer, Jr., Washington, D.C., for defendant.

OPINION

SPECTOR, Judge.

The issues in this tax case are whether various sums advanced by plaintiff1 to a number of business entities, and not repaid, are debts, and if they are, whether they constitute business, rather than nonbusiness debts.

Section 166 of the Internal Revenue Code of 1954, as amended, allows as a deduction any debt which becomes worthless within the taxable year. Alternatively, at the discretion of...

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