Court of Appeals for the First Circuit December 3, 1973, 73-1282 (Marshall French and Susan French v. United States)

ALDRICH, Senior Circuit Judge.

This is an action to recover a payment of additional income tax for the year 1964 assessed as a result of the Commissioner’s classification of a claimed business bad debt as a nonbusiness one. Nonbusiness bad debts are equated with short term capital losses, and deductions on account thereof are subject to those limitations. Int.Rev. Code of 1954, § 166.