FEGAN v. COMMISSIONER
United States Tax Court
Held: Petitioner is not entitled to a bad debt deduction in 1977 because the debt arising from his payment as guarantor on the note of a corporation in which he owned stock was a non-business debt that did not become totally worthless in 1977.
1Opinion of the Court
ROBERT J. FEGAN AND MARION E. FEGAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
FEGAN v. COMMISSIONER
Docket No. 7247-81.
United States Tax Court
T.C. Memo 1982-435; 1982 Tax Ct. Memo LEXIS 311; 44 T.C.M. (CCH) 636; T.C.M. (RIA) 82435;
July 29, 1982.
Held: Petitioner is not entitled to a bad debt deduction in 1977 because the debt arising from his payment as guarantor on the note of a corporation in which he owned stock was a non-business debt that did not become totally worthless in 1977.
Murray F. Hardesty and Thomas F. Puckett, for the petitioners.
Alan M. Jacobson, for the…
2Cases cited15 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Putnam v. CommissionerSupreme Court of the United States · 1956
- United States v. GeneresSupreme Court of the United States · 1972
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
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