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131780P.pdf   05/12/2014  Harry Haury  v.  CIR
   U.S. Court of Appeals Case No:  13-1780
   The United States Tax Court   
[PUBLISHED] [Loken, Author, with Murphy and Smith, Circuit Judges] Civil case - Federal Tax. Taxpayer's IRA contribution was timely and it was a qualifying partial rollover under Section 408(d)(3)(D), and taxpayer was entitled to reduce his taxable IRA distribution by the amount of the rollover; the Tax Court did not err in disallowing taxpayer's "worthless debt" deductions as taxpayer failed to prove that his dominant motivation for making the loans in question made them deductible bad debts when they became worthless.