Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal Revenue

MERRILL, Circuit Judge:

Herbert W. Dustin, the taxpayer, 1 appeals from a decision of the Tax Court, 53 T.C. 491 (1969), upholding the Commissioner’s assessment of deficiency in income tax for 1961 in the amount of $4,286.77 and addition to tax of $383.76 for late filing of the 1961 tax return.

BAD-DEBT DEDUCTION

With a Mr. and Mrs. Leswing, taxpayer in 1958 entered into a partner ship, known as Century Schoolbook Press, for the purpose of publishing textbooks for submission to and adoption by the California school system. Taxpayer was a limited partner, and received a percentage interest in…