This section contains the nature of the case and procedural background.

Cristina (P) was divorced from her husband, Baxter (H), and was granted custody of her two minor children. H agreed to pay $300 per month child support, and he failed to make full payment of those obligations from 1972-78. He was in arrears by $4,325, and by the end of 1979, he was in arrears another additional $3,000. On their 1978 return, P treated the $4,325 as a nonbusiness bad debt and deducted that amount from gross income as a short-term capital loss. P did the same in 1979 with the $3,000. The deductions were disallowed. P diligently attempted to collect the monies.

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