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SMARTT v. COMMISSIONER

Docket No. 19221-90.

65 T.C.M. 1962 (1993)

T.C. Memo. 1993-65

Billie H. Smartt and Margaret A. Smartt v. Commissioner.

United States Tax Court.

Filed February 25, 1993.

Attorney(s) appearing for the Case

Terry F. Satterwhite and Steve D. Noecker, 102 S. Tejon, Colorado Springs, Colo., for the petitioners. Richard D. D'Estrada and Ann M. Welhaf, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

Year                                   Deficiency

1984 ...............................    $71,334
1985 ...............................     87,212

The issues for decision are: (1) Whether petitioners' losses from bad debts for tax years 1984 and 1985 are losses from nonbusiness...

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