T.C. Memo. 1996-221
UNITED STATES TAX COURT
PAUL G. GUBBINI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23708-93. Filed May 7, 1996.
Marie L. DeMarco and J. Paul Raymond, for petitioner.
Francis C. Mucciolo, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: Respondent determined a deficiency of $58,883
in petitioner’s 1989 Federal income tax. After concessions, the
issues remaining for decision are: (1) Whether petitioner is
entitled to a business bad debt deduction pursuant to section
166(a)(1) for the worthlessness of certain loans and advances
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