Category: Bankruptcy, Insolvency & Debt Discharge;
Individuals Subject: Bad Debt Title: Bad Debts: Renewed Notes IRC Sections: 166 Filename: 1214.html Date Produced: 03/95 Copyright 1998, The Tax Resource Group. All rights reserved. Telephone
800-578-3498. Internet: www.taxresourcegroup.com 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. |