Legal Opinion

Barnard v. Commissioner

United States Tax Court

Decided December 27, 1963No. Docket No. 1131-62Unpublished

1Opinion of the Court

Robert L. Barnard v. Commissioner.

Barnard v. Commissioner

Docket No. 1131-62.

United States Tax Court

T.C. Memo 1963-338; 1963 Tax Ct. Memo LEXIS 6; 22 T.C.M. (CCH) 1773; T.C.M. (RIA) 63338;

December 27, 1963

Benjamin Becker, for the petitioner. Frederic S. Kramer, for the respondent.

OPPER

Memorandum Findings of Fact and Opinion

OPPER, Judge: A deficiency in 1959 income tax of $220 has been determined. The issue is whether cash advances made by petitioner (1) constituted an allowable nonbusiness bad debt under section 166(d), I.R.C. 1954, or, if not, (2) constituted a deductible loss under section…

2Cases cited5 opinions

  1. Hans Zimmerman and Clara Zimmerman, Apellants v. United States of America and District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  2. Commissioner of Internal Revenue v. ParkCourt of Appeals for the Third Circuit · 1940
  3. Park v. CommissionerUnited States Board of Tax Appeals · 1938
  4. Milton Bradley Co. v. United StatesCourt of Appeals for the First Circuit · 1944
  5. Nichols v. CommissionerUnited States Tax Court · 1958

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