Ross D. Hogue and Mildred M. Hogue v. Commissioner of Internal Revenue

CHRISTENSEN, Senior District Judge.

Appellants 1 brought this action in the United States Tax Court for a rede-termination of a 1964 income tax deficiency determined by the Commissioner of Internal Revenue. The item in dispute was the tax assessed on $19,345.83 claimed in the return to be deductible as a business bad debt arising from appellant’s guaranty of certain obligations of a furniture business in alleged advancement of his accounting practice. Consistently with the ruling of the Commissioner, the Tax Court concluded that payments by appellant of the guaranteed loans did not create…