- 2 - Respondent determined a deficiency in petitioners’ Federal income tax of $1,716 for the taxable year 1999. After concessions by petitioners, the sole issue remaining for decision is whether petitioners are entitled to a bad debt deduction. 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. Petitioners resided in Madera, California, on the date the petition was filed in this case. From November 1998 through May 1999, petitioner husband (petitioner) worked as an independent contractor for Anderson Mortgage Group, Inc. (Anderson), as a loan officer. In this capacity, petitioner earned commissions for real estate mortgage loans which he procured, funded, and closed. Petitioner’s contract with Anderson provided that either party had the right to terminate the contract for any reason by providing the other party with 24 hours’ written notice. The contract further provided that upon termination “any loans procured but not funded or closed will become the property of Anderson Mortgage and no compensation will be due” petitioner. In May 1999, Anderson terminated the contract after giving petitioner the required 24 hours’ notice. In July 1999, an attorney retained by petitioner wrote Anderson, stating that petitioner was “due approximatelyPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011