Johnson v. Commissioner

JERRY E. SMITH, Circuit Judge: *

H. Dee Johnson, Jr., appeals a decision of the United States Tax Court, which upheld the Internal Revenue Service’s findings of deficiencies in the tax reported on certain of his returns. Finding no error, we affirm.

I

On September 3, 1991, Johnson filed a petition under chapter 7 of the Bankruptcy Code. 1 Johnson’s assets that were transferred to the estate included a $153,000 business debt payable to him. After becoming an asset of the estate, the debt became worthless, resulting in a new operating loss to the estate of $153,000. The estate also included two…