McDONNELL v. COMMISSIONER

Docket No. 25952-87.

58 T.C.M. 1351 (1990)

T.C. Memo. 1990-60

Daniel A. McDonnell and Karen A. McDonnell v. Commissioner.

United States Tax Court.

Filed February 12, 1990.


Attorney(s) appearing for the Case

William Randolph Klein, 2071 Main St., Sarasota, Fla., for the petitioners. Charles A. Baer, for the respondent.


Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

In a notice of deficiency dated May 6, 1987, respondent determined a deficiency of $1,266 in petitioners' Federal income tax for 1983.

The issues are (1) whether petitioners are entitled to a business or a nonbusiness bad debt deduction under section 1661; and (2) whether the debt became worthless in 1983.

Findings of Fact

Some of the facts have...

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