Richard C. Hunsaker and Virginia A. Hunsaker v. Commissioner of Internal Revenue Service, Richard C. Hunsaker and Virginia A. Hunsaker, Cross-Appellees v. Commissioner of Internal Revenue Service, Cross-Appellant

615 F.2d 1253 80-1 USTC P 9331 Richard C. HUNSAKER and Virginia A. Hunsaker, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee. Richard C. HUNSAKER and Virginia A. Hunsaker, Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Cross-Appellant. Nos. 76-1349, 76-1842. United States Court of Appeals, Ninth Circuit. April 1, 1980. Charles D. Cummings (argued), Los Angeles, Cal., for appellants. Francis J. Gould (argued), Dept. of Justice-Washington, D.C., for Commissioner of I.R.S.; Scott B. Crampton, Asst. Atty. Gen., Washington, D.C., on brief. Before GOODWIN, WALLACE and FARRIS, Circuit Judges. GOODWIN, Circuit Judge: 1 Richard C. and Virginia A. 1 Hunsaker, taxpayers, appeal a Tax Court judgment upholding in substance the Commissioner's claim of deficiencies for 1968, 1969 and 1970. At issue is the correct treatment of deductions for bad debts during the respective years. The Commissioner cross-appeals from the court's separate decision that payments made by Richard as guarantor on performance bonds were deductible from ordinary income. We affirm the judgment on appeal and reverse the judgment on the cross-appeal. 2 Richard Hunsaker and his father, S. V.…