Vinnik v. Director, Division of Taxation

CRABTREE, J.T.C.

Plaintiff seeks review of a deficiency in gross income tax determined by defendant for taxable year 1987. The amount of the deficiency is $43,867.43, plus interest. The deficiency arises from defendant’s disallowance of nonbusiness bad debt losses amounting to $995,557 deducted on plaintiff’s 1987 gross income tax return. In his complaint plaintiff increased his claimed loss on one transaction from $742,202 to $1 million. This particular loss, plaintiff alleged, arose from plaintiff’s guaranty of a loan and payment thereof in 1987 upon the debtor’s default.

The parties have…