Schnell v. Commissioner of Taxation & Finance

Proceeding pursuant to CPLR article 78 (initiated in this Court pursuant to Tax Law § 2016) to review a determina*978tion of respondent Tax Appeals Tribunal which denied petitioners’ claimed bad debt deduction.

Petitioner Joseph Schnell was the sole proprietor of a plumbing business. Due to the allegedly improper termination of several contracts, the business never received any income. In 1999 and 2000, petitioners claimed bad debt deductions of $28,500 and $30,000 on their personal income tax returns in amounts purported to represent income that Schnell was entitled to receive as wages for his…