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PIERCE v. COMMISSIONER

Docket No. 24782-84.

52 T.C.M. 1036 (1986)

T.C. Memo. 1986-552

William L. Pierce and Paula Pierce v. Commissioner.

United States Tax Court.

Filed November 18, 1986.

Attorney(s) appearing for the Case

William L. Pierce, pro se. John Naumann Strange, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in the amount of $8,783.12 in petitioners' Federal income tax for the taxable year ended December 31, 1980. The sole issue is whether a $25,000 loss sustained by petitioners should be treated as a business bad debt under section 166(a)1, deductible as an ordinary loss, or as a nonbusiness bad debt deductible as a short-term capital loss...

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