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The Tax Resource Group: Professional Tax Research Material, Resources, and Consulting

Category: Bankruptcy, Insolvency & Debt Discharge; Individuals
Subject: Bad Debt
Title: Bad Debts: Renewed Notes
IRC Sections: 166
Filename: 1214.html
Date Produced: 03/95

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Per your instructions, I have spent a total of three hours searching for a case or published ruling in which the taxpayer was allowed to claim a bad debt deduction notwithstanding concurrent renewal of the debt in question.

I have performed (within the confines of the budget) a full-text word search on all federal income tax cases and published rulings. I have also word-searched various commentary and annotation-style tax services.

Based on my work, I was unable to locate a case with a favorable holding. Although one can never know with certainty what might be found based on a more extensive search, I do not feel that investment of additional time would yield positive results. I saw nothing in the cases that I retrieved that encouraged me to think a court might hold in favor of the taxpayer in the circumstances you have described.