Charles Kadlec and Leslie C. Kadlec, (1996)

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Charles Kadlec and Leslie C. Kadlec, (1996)

T.C. Memo. 1996-119

UNITED STATES TAX COURT CHARLES KADLEC AND LESLEY C. KADLEC, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22506-94. Filed March 12, 1996. Lisa J. Steele, for petitioners.

Melanie M. Garger, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined a deficiency of $50,115 in petitioners' 1988 Federal income tax. Respondent further determined an addition to tax pursuant to section 6651(a)(1)1 in the amount of $12,529.

After concessions,2 the sole issue remaining for decision is whether petitioners are entitled to a bad debt deduction of $182,451.03 for the 1988 taxable year.

FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and attached e...

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