Myer B. Barr and Estate of Diana L. Barr - Page 2




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               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 and Procedure, unless                    
          otherwise indicated.  References to petitioner are to Myer B.               
          Barr.                                                                       
               The issues for decision are:  (1) Whether for 1993                     
          petitioners are entitled to a $100,000 nonbusiness bad debt                 
          deduction related to a transaction with Super City Meats, Inc.              
          (Super City Meats).  We hold they are.  (2) Whether for 1993                
          petitioners are entitled to charitable contribution deductions in           
          excess of the amount allowed by respondent.  We hold they are to            
          the extent set forth below.                                                 
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the accompanying exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          in this case was filed, petitioner resided in Palm Beach,                   
          Florida.                                                                    
               For convenience, we combine our findings of fact with our              
          opinion under each separate issue heading.1                                 
          Issue 1.  Bad Debt                                                          
               Respondent determined that for 1993 petitioners were not               
          entitled to a $100,000 nonbusiness bad debt deduction related to            
          a transaction with Super City Meats.                                        

               1    We have considered each of the parties' arguments and,            
          to the extent that they are not discussed herein, find them to be           
          unconvincing.                                                               


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