Larry J. and Angela L. Siggelkow - Page 1
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T.C. Memo. 1999-44
UNITED STATES TAX COURT
LARRY J. AND ANGELA L. SIGGELKOW, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2550-97. Filed February 10, 1999.
R. Glen Woods, for petitioners.
Wendy S. Harris, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a deficiency in
petitioners’ 1992 Federal income tax in the amount of $24,993.
The issue for our consideration is whether petitioners are
entitled to take an ordinary loss deduction for a business bad
debt as allowed by section 166.1 Petitioners contend that, in
1 Unless otherwise stated, all section references are to the
Internal Revenue Code in effect for the taxable year in issue,
and all Rule references are to the Tax Court Rules of Practice
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Last modified: May 25, 2011