57. Last year your client, Barney Bumluck, worked part-time for Timely Tax Return Preparation Service. Barney was promised an hourly wage plus a commission. He worked under this arrangement from early February until April 15. His accrued pay amounted to $900 plus $120 of commissions.

When he went to collect his pay, however, he found only a vacant office with a sign on the door reading “Nothing is sure but death and taxes.” Can Barney take a bad debt deduction for the wages and commission he was unable to collect?

Research Aid: Reg. Section 1.166–1(e)