I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal Revenue

VAN OOSTERHOUT, Circuit Judge.

Taxpayer I. Hal Millsap, Jr., 1 has filed a timely petition for review of the deci sion of the Tax Court upholding certain deficiency determinations made by the Commissioner with respect to income tax liability for the years 1957, 58, 59 and 60 aggregating $27,145.83. The opinion of the Tax Court is reported at 46 T.C. 751.

Taxpayer urges that the Tax Court committed error in the following respects :

I. In holding that $83,857.87 outstanding in loans made by taxpayer to Millsap Oil and Gas Company (hereinafter called MOG) which became worthless in 1960 cbnstituted…