Madeline Cook - Page 1
















                                 T.C. Memo. 2000-253                                  


                               UNITED STATES TAX COURT                                


                            MADELINE COOK, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7592-99.                   Filed August 10, 2000.           

               Joseph D. Anroman, for petitioner.                                     
               Michael P. Breton, for respondent.                                     


                                 MEMORANDUM OPINION                                   

               WELLS, Chief Judge:  Respondent determined deficiencies in             
          petitioner's 1994 and 1995 Federal income taxes in the amounts of           
          $5,750 and $18,541 respectively.                                            
               The issues for decision are:  (1) Whether petitioner is                
          entitled to a $120,800 business bad debt deduction for 1994 (with           





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