- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011