Elmer J. Thompson and Helen H. Thompson v. Commissioner of Internal Revenue

Respondent Commissioner of Internal Revenue determined an income tax deficiency of $150 for each of the petitioners, Elmer J. Thompson and Helen H. Thompson, husband and wife, for the calendar year 1949. Their claims of bad debt loss arising out of transactions entered into in 1944 and 1946 with one Jack Miller were disallowed. The determinations of the Commissioner were sustained by-the Tax Court of the United States.

The taxpayers have petitioned this Court to review the separate decisions of the Tax Court ordering and deciding that there is a deficiency in income tax of $150 for the year 1949 for each of them. These decisions were made pursuant to that' Court’s ‘ Memorandum Opinion filed January 10,1955. As will be seen, the separate decisions arose from identical facts. The petitions for review have been argued and are to be considered together.

At a hearing in the Tax Court the Commissioner and the taxpayers stipulated, among other matters, as follows:

Partial payments going to make up the $14,700 were made on the dates stated in the stipulation covering a period from February' 6, 1945; to April "6, 1946.

The -stipulation' also recited ■ that the petitioners’ United…