- 4 - Schedule C, Profit or Loss From Business, to arrive at their adjusted gross income. The loans were made in petitioner’s trade or business of being an employee and were made to enable him to maintain his employment with KPS. Although petitioner claimed $84,734 as a business bad debt on his return, at trial he substantiated loans to KPS of $86,040. Petitioners failed to report the following items of income on their 1996 income tax return: Income Item Amount Interest $3,475 State tax refund 105 Taxable pensions 29,835 Computational error 10,000 On their January 9, 2002, notice of deficiency, respondent allowed $85,009 as a business bad debt deduction and treated it as an itemized deduction on Schedule A, Itemized Deductions. The amount respondent allowed is $275 greater than the amount petitioners claimed on their 1996 return. OPINION The issues we consider arise from circumstances under which petitioner lent his solely owned corporation capital so that it could continue its operations, including the payment of salaries. Petitioner was a salaried employee of the corporation and was in the business of being an employee. The loans became worthless during the 1996 tax year, and petitioner claimed the loss inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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