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STEPHENS GROUP, INC. v. COMMISSIONER

Docket No. 28457-92.

69 T.C.M. 2358 (1995)

T.C. Memo. 1995-158

Stephens Group, Inc., formerly Stephens, Inc., et al. v. Commissioner.

United States Tax Court.

Filed April 6, 1995.

Attorney(s) appearing for the Case

Jackson Farrow, Jr., for the petitioner. Robert J. Misey, Jr., for the respondent.

Memorandum Opinion

LARO, Judge:

Respondent moves pursuant to Rule 1211 for an order granting partial summary judgment in her favor on the issue of whether a loan and pledge of funds made by Real Properties, Inc. (RPI), to or for the benefit of United Pacific Trading Co., Inc. (UPT), were deductible as bad debts for Stephens Group, Inc.'s (petitioner's) taxable year ended May 31, 1986.

The facts presented below are based...

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