- 4 - term capital loss of $3,000 in each year. In the notice of deficiency, respondent disallowed the $3,000 capital loss for each of the taxable years 1996 and 1997. Respondent also made the following adjustments to petitioners’ Schedule A deductions:2 1996 1997 Claimed Allowed Dis- Claimed Allowed Dis- allowed allowed Lodging $2,488 $-0- $2,488 $1,058 $-0- $1,058 Meals & 1,216 1,072 114 -- -- -- entertain- ment Protective 693 -0- 693 529 -0- 529 clothing Union dues 292 -0- 292 71 -0- 71 Total $4,689 $1,072 $3,587 $1,658 $ -0- $1,658 Bad Debt Deduction Section 166(a) generally allows a deduction for debts that become wholly or partially worthless within the taxable year. A business bad debt is fully deductible from ordinary income; however, a nonbusiness bad debt of a taxpayer other than a corporation is treated as a short-term capital loss. Sec. 166(d)(1). A nonbusiness bad debt is defined as a debt other than: “(A) a debt created or acquired (as the case may be) in connection with a trade or business of the taxpayer; or (B) a debt the loss from the worthlessness of which is incurred in the 2 Amounts reflect concessions made by the parties.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011