John W. Hough and Louise C. Hough v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
1Opinion of the Court
RIPPLE, Circuit Judge.
Taxpayers John and Louise Hough claimed a business-related bad debt deduction in their 1978 tax return, pursuant to 26 U.S.C. § 166. 1 The Commissioner of Internal Revenue (Commissioner) disallowed this deduction and, on August 12,1985, issued a notice of deficiency. The Houghs filed a petition with the United States Tax Court contesting the deficiency determination and alleging that the Internal Revenue Service (IRS) had violated 26 U.S.C. § 7605(b) by performing a prohibited second inspection of their 1978 books of account. The Tax Court found that the taxpayers had…
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