Richard M. Gooding and Marcella M. Gooding v. Commissioner of Internal Revenue

J. SPENCER BELL, Circuit Judge.

Taxpayers petition for review of a decision of the Tax Court determining a deficiency of $221.00 in taxpayers’ income tax for the year 1958. In the hearing below taxpayers asserted two claims: first, that a bad debt deduction of $1,-000.00 was improperly denied them, and that, in fact, there was an overpayment of tax in the amount of $351.00; and second, that an overpayment of approximately $10,000.00 on their 1951 tax should have been allowed them by the Court below as a credit on their 1958 tax. Taxpayers abandoned their first claim, both in the Court below…