Edmund Thomas Gulledge, Sr., and Lucy Coulter Gulledge, Husband and Wife v. Commissioner of Internal Revenue

SOPER, Circuit Judge.

The question on this appeal is whether certain loans, which had been made by the taxpayer to a corporation and had become, worthless in the years 1951 and 1952, constituted business bad debts deductible in full from gross income under § 23 (k) (1) of the Internal Revenue Code, or non-business debts to be treated as losses from the sale or exchange of capital assets held for not more than six months, and. therefore deductible in a limited amount under § 23 (k) (4). 1. Edmund T. Gulledge, the taxpayer, and his wife, who is a party only because joint returns were filed, made…