- 3 - During the years in issue, petitioner operated a heating and plumbing service. On their 1994 and 1995 Federal income tax returns, petitioners claimed business bad debt deductions in the amounts of $1,342 and $2,850, respectively. In the notice of deficiency, respondent determined that petitioners are not entitled to the bad debt deductions because the revenue corresponding to such claimed deductions never was included in petitioners' income. Petitioners received interest income from First Union National Bank of Florida in 1994 in the amount of $794. In the notice of deficiency, respondent determined that petitioners had not included this income on their 1994 Federal income tax return. Petitioners contend that both the interest income and the income that the bad debt deductions represent were included in the amount set forth on the gross receipts line of the Schedules C attached to their 1994 and 1995 Federal income tax returns. Petitioners' 1994 and 1995 Federal income tax returns were prepared by a tax preparation firm that used worksheets to prepare those tax returns. Petitioners destroyed these worksheets after their 1994 and 1995 Federal income tax returns were filed. Section 166(a) provides that there shall be allowed as a deduction any debt which becomes worthless within the taxable year. However, worthless debts arising from unpaid wages, salaries, fees, rents, and similar items of taxable income arePage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011