T.C. Memo. 1997-262
UNITED STATES TAX COURT
ROBERT A. READ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21250-94. Filed June 11, 1997.
LeRoy Boyer, for petitioner.
Donald E. Edwards and Bruce K. Meneely, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a $173,098 deficiency
in petitioner's 1984 Federal income tax.
The issues in this case arise out of a claimed net operating
loss (NOL) carryback from 1986 to 1984. The NOL carryback is
based on a bad debt deduction claimed by petitioner on his 1986
individual Federal income tax return. Petitioner's 1986 bad debt
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