Edde

The taxpayers herein filed a claim for refund of taxes paid in the years 1969 through 1973, by filing amended returns for these years. In Part II, Explanation of Changes, in the 1972 return (Form 1040X), taxpayers stated that they sustained a "business bad debt loss” in 1972 in the amount of $140,087.33 as the ground for a refund of taxes paid that year. As to other years they claimed net operating loss carrybacks and carryover. IRS disallowed the claims, reasoning that the transaction creating the loss had not resulted in a "business bad debt * * * [but] a non-business bad debt which is…