Legal Opinion

Dean v. Commissioner

United States Tax Court

Decided March 31, 1970No. Docket No. 3692-68Unpublished

Petitioner was a 50 percent partner and subsequently sole proprietor of a bookkeeping and tax service business. The business made a short-term loan of $1,000 to one of its clients, which loan was never repaid. In 1963, the business purchased a 31-year old house and garage. The house was converted for use as an office building by the business, and the garage was leased to a client for use as ashop building.

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Petitioner was a 50 percent partner and subsequently sole proprietor of a bookkeeping and tax service business. The business made a short-term loan of $1,000 to one of its clients, which loan was never repaid. In 1963, the business purchased a 31-year old house and garage. The house was converted for use as an office building by the business, and the garage was leased to a client for use as ashop building. Held: 1. The respondent correctly determined that the $1,000 business bad debt did not become totally worthless during the taxable year 1963 under the provisions of section 166(a)(1),…

1Opinion of the Court

Helen N. Dean and Forrest V. Dean v. Commissioner.

Dean v. Commissioner

Docket No. 3692-68.

United States Tax Court

T.C. Memo 1970-75; 1970 Tax Ct. Memo LEXIS 280; 29 T.C.M. (CCH) 338; T.C.M. (RIA) 70075;

March 31, 1970, filed

Petitioner was a 50 percent partner and subsequently sole proprietor of a bookkeeping and tax service business. The business made a short-term loan of $1,000 to one of its clients, which loan was never repaid. In 1963, the business purchased a 31-year old house and garage. The house was converted for use as an office building by the business, and the garage was leased to a…

2Cases cited11 opinions

  1. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  2. Casey v. CommissionerUnited States Tax Court · 1962
  3. Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
  4. Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
  5. Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954

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