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FARRAR v. COMMISSIONER

Docket No. 7258-85.

55 T.C.M. 1628 (1988)

T.C. Memo. 1988-385

Frank L. Farrar and Patricia J. Farrar v. Commissioner.

United States Tax Court.

Filed August 16, 1988.

Attorney(s) appearing for the Case

Danny R. Smeins, St. Paul, Minn., for the petitioners. Robert F. Cunningham, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1979 in the amount of $107,481.77, and an addition to tax in the amount of $26,870.44 pursuant to section 6651(a)(1).1 After concessions, the issues remaining for decision are as follows: (1) whether petitioners may fully deduct, as business bad debts, payments made pursuant to personal...

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