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OSTERBAUER v. COMMISSIONER

Docket No. 10926-93.

70 T.C.M. 988 (1995)

T.C. Memo. 1995-490

Sylvia Osterbauer and Estate of Joseph Osterbauer, Deceased, Sylvia Osterbauer, Personal Representative v. Commissioner.

United States Tax Court.

Filed October 10, 1995.

Attorney(s) appearing for the Case

Don C. St. Peter, Missoula, Mont., for the petitioners. Thomas E. Ritter, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FAY, Judge:

By statutory notice of deficiency, respondent determined a deficiency of $12,280 in the 1985 Federal income tax of Joseph Osterbauer, now deceased (decedent), and Sylvia Osterbauer (petitioner).

The issue for decision1 is whether petitioners are entitled to deduct in 1985 a worthless debt as a business bad debt under...

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