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Respondent determined a deficiency in petitioners’ Federal
income taxes of $1,395 and $1,132 for the 1996 and 1997 taxable
years, respectively.
After concessions by the parties,1 the issues for decision
are: (1) Whether petitioners are entitled to claim a “long-term
capital loss” attributable to a nonbusiness bad debt; and (2)
whether petitioners are entitled to Schedule A, Itemized
Deductions for 1996 and 1997.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in South Haven, Michigan.
Petitioners are husband and wife. References to petitioner in
the singular are to Gregory G. Webb.
During the years at issue, petitioner was a boilermaker.
Petitioners also operated a small “Ma and Pa” grocery store in
South Haven, Michigan.
On September 8, 1987, petitioner lent Charles Garner (Mr.
1 Respondent concedes that a mathematical error was made
in the notice of deficiency. The correct amount disallowed on
petitioners’ Schedule A, Itemized Deductions, for 1996 is $3,587,
which remains in dispute.
Petitioners concede the disallowance of business losses
claimed on their Schedule C, Profit or Loss From Business, in the
amounts of $2,603 and $1,479 for taxable years 1996 and 1997,
respectively.
The parties also concede that the disallowed amount of
petitioners’ itemized deductions for 1997 should be reduced to
$1,658, which remains in dispute.
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