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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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