T.C. Memo. 1999-44 UNITED STATES TAX COURT LARRY J. AND ANGELA L. SIGGELKOW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2550-97. Filed February 10, 1999. R. Glen Woods, for petitioners. Wendy S. Harris, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined a deficiency in petitioners’ 1992 Federal income tax in the amount of $24,993. The issue for our consideration is whether petitioners are entitled to take an ordinary loss deduction for a business bad debt as allowed by section 166.1 Petitioners contend that, in 1 Unless otherwise stated, 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 (continued...)Page: 1 2 3 4 5 6 7 Next
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