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" The debt is one or the other in its entirety, for the Code does not provide for its allocation in part to business and in part to nonbusiness. In determining whether a bad debt is a business or a nonbusiness obligation, the Regulations focus on the relation... "
Structure and Internal Procedures: Recommendations for Change : a ... - Page 16
by United States. Commission on Revision of the Federal Court Appellate System - 1975 - 273 pages
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1973 - 824 pages
...entirety, for the Code does not provide for its allocation in part to business and in part to nonbusiness. o deduction shall be allowed in respect of losses...sales or exchanges of property (other than losses bad debt and the aforementioned desirable tax consequences then ensue. The present case turns on the...
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