Eberhart v. Commissioner
United States Tax Court
Petitioner had made 60 loans to various individuals and corporations over a 26-year period. Certain loans made in 1968 and 1970 became worthless in 1971. Held, petitioner was not in the business of lending money during 1968 to 1971, and losses sustained in 1971 are deductible only as nonbusiness bad debts. Held further, attorneys' fees paid by petitioners in 1971 are not allowable as a deduction either under section 162 or section 212, I.R.C. 1954.
1Opinion of the Court
RAY EBERHART and PEGGY EBERHART, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Eberhart v. Commissioner
Docket No. 4733-75.
United States Tax Court
T.C. Memo 1977-155; 1977 Tax Ct. Memo LEXIS 289; 36 T.C.M. (CCH) 660; T.C.M. (RIA) 770155;
May 23, 1977, Filed
Petitioner had made 60 loans to various individuals and corporations over a 26-year period. Certain loans made in 1968 and 1970 became worthless in 1971. Held, petitioner was not in the business of lending money during 1968 to 1971, and losses sustained in 1971 are deductible only as nonbusiness bad debts. Held further,…
2Cases cited12 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- United States v. Simon W. Henderson, Jr., Independent for the Estate of Louise R. Henderson, DeceasedCourt of Appeals for the Fifth Circuit · 1967
- Daniel S. W. Kelly v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Zivnuska v. CommissionerUnited States Tax Court · 1959
- Kelly v. CommissionerUnited States Tax Court · 1955
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