COX v. C.I.R.

No. 94-41087.

68 F.3d 128 (1995)

Richard W. COX and Kay L. Cox, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

November 6, 1995.


Attorney(s) appearing for the Case

John Cavett McDuff, Austin, TX, for Appellant.

David L. Jordan, Acting Chief Counsel, I.R.S. David English Carmack, Gary R. Allen, Chief, Andrea R. Tebbets, Linda Mosakowski, Appellate Section, Lorretta Argrett, Asst. Atty. Gen., Tax Division, Dept. of Justice, Washington, DC, for appellee.

Before WISDOM, DUHÉ and BARKSDALE, Circuit Judges.


WISDOM, Circuit Judge:

Mr. and Mrs. Richard Cox, plaintiff/appellants, appeal a decision of the United States Tax Court upholding the findings of the Commissioner of Internal Revenue (Commissioner) regarding the plaintiffs' 1987 tax return. The plaintiffs challenge the Commissioner's decision to disallow their bad debt deduction for a loan to their wholly-owned corporation. Additionally, the plaintiffs assert that a nonjudicial foreclosure on their personal property...

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