Herrera v. Commissioner

PER CURIAM: *

This is an appeal from a Tax Court decision sustaining a determination by the Commissioner of Internal Revenue (“Commissioner”) that Appellants Dr. Juan and Susana Herrera improperly took a business bad debt deduction based upon payments Dr. Herrera’s company made to satisfy the debt of another company he owned. Because the Herreras have not shown that Dr. Herrera’s company was legally obligated to satisfy the debt, we AFFIRM.

I

In 1978, Dr. Herrera, a mechanical and metallurgical engineer, and his colleague, Dr. Steve Stafford, formed an engineering consulting company called…