T.C. Memo. 1999-104
UNITED STATES TAX COURT
JOSEPH F. AND DOROTHY M. GERMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12954-96. Filed March 31, 1999.
L. Patrick O’Day, Jr., for petitioners.
Gail K. Gibson, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: Respondent determined a deficiency in
petitioners’ 1990 Federal income tax in the amount of $21,890.
The issue for decision is whether certain purported loans made by
petitioner husband (hereinafter petitioner) are deductible as a
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