Max Axelrod v. Commissioner of Internal Revenue

BOYD, District Judge.

This appeal from the decision of the Tax Court of the United States 1 turns upon the interpretation of Section 166(f) of the Internal Revenue Code of 1954, Title 26 U.S.C. As best we can determine, this is the first cause directly calling for judicial construction of this section, 2 which provides as follows:

“§ 166. Bad debts—

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“(f) Guarantor of certain noncorpo-rate obligations. — A payment by the taxpayer (other than a corporation) in discharge of part or all of his obligations as a guarantor, endorser, or indemnitor of a noncorporate obligation the proceeds of…