Clair and Judith Worthington - Page 3




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               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 are              




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