Markle v. Commissioner

OPINION.

Tietjens, Judge:

The first issue, which is common to all three taxable years, involves the question of' whether petitioner is entitled to deductions for all or any part of his disbursements to the Sales Company in the amounts of $5,058.39 in 1943, $3,226.60 in 1944, and $2,879.31 in 1945. Petitioner’s primary contention is that those amounts were paid by him as a guarantor and constituted business bad debts deductible in full under section 23 (k) (1), Internal Revenue Code. On the other hand, respondent contends that the disbursements were not made by the petitioner as a guarantor;…