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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