United States Tax Court December 7, 1981, Docket No. 866-79 (Benak v. Commissioner)

lead-opinion

Simpson, Judge-.

The Commissioner determined a deficiency of $25,509.03 in the petitioners’ Federal income tax for 1974. After a concession by the petitioners, the issues for decision are: (1) Whether the petitioners may deduct, as a business bad debt, an amount paid in satisfaction of their obligation as guarantors of a loan; and (2) whether the petitioners may deduct the amount of