Keating v. Commissioner
United States Tax Court
On their 1978 joint Federal income tax return, petitioners reported a nonbusiness bad debt in the amount of $ 567,424. Under the provisions of sec. 166(d), I.R.C. 1954, as amended, only $ 116,800 thereof was deductible as an offset against petitioners' short-term capital gain.
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On their 1978 joint Federal income tax return, petitioners reported a nonbusiness bad debt in the amount of $ 567,424. Under the provisions of sec. 166(d), I.R.C. 1954, as amended, only $ 116,800 thereof was deductible as an offset against petitioners' short-term capital gain. Held: For purposes of calculating the limitations on investment interest deductions under sec. 163(d), I.R.C. 1954, as amended, nonbusiness bad debts are treated as "investment expenses" only to the extent they are currently deductible. Accordingly, only $ 116,800 of petitioners' nonbusiness bad debts are treated as…
1Opinion of the Court
Charles H. Keating and Mary Elaine Keating, Petitioners v. Commissioner of Internal Revenue, Respondent
Keating v. Commissioner
Docket No. 41733-84
United States Tax Court
89 T.C. 1071; 1987 U.S. Tax Ct. LEXIS 165; 89 T.C. No. 73;
November 30, 1987. November 30, 1987, Filed
Decision will be entered under Rule 155.
On their 1978 joint Federal income tax return, petitioners reported a nonbusiness bad debt in the amount of $ 567,424. Under the provisions of sec. 166(d), I.R.C. 1954, as amended, only $ 116,800 thereof was deductible as an offset against petitioners' short-term capital gain. Held: For…
2Cases cited12 opinions
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- Commissioner v. EngleSupreme Court of the United States · 1984
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- J. C. Penney Co. v. CommissionerUnited States Tax Court · 1962
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