Heinz v. Commissioner
United States Board of Tax Appeals
1. Where all essential facts indicating worthlessness of a debt were known to the petitioner in 1927, he is not entitled to charge off the debt and deduct the amount thereof from gross income for 1928. 2. On February 26, 1929, petitioner received a check for $4,391.60 from a syndicate of which he was a member, which amount represented "interest and dividend adjustments," and was the final distribution of profits upon termination of the syndicate's operations.
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1. Where all essential facts indicating worthlessness of a debt were known to the petitioner in 1927, he is not entitled to charge off the debt and deduct the amount thereof from gross income for 1928. 2. On February 26, 1929, petitioner received a check for $4,391.60 from a syndicate of which he was a member, which amount represented "interest and dividend adjustments," and was the final distribution of profits upon termination of the syndicate's operations. All events which fixed the amount of petitioner's distributive share of the syndicate's profits had transpired on or before November…
1Opinion of the Court
HENRY C. HEINZ, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Heinz v. Commissioner
Docket No. 55480.
United States Board of Tax Appeals
28 B.T.A. 276; 1933 BTA LEXIS 1146;
June 6, 1933, Promulgated
1. Where all essential facts indicating worthlessness of a debt were known to the petitioner in 1927, he is not entitled to charge off the debt and deduct the amount thereof from gross income for 1928.
2. On February 26, 1929, petitioner received a check for $4,391.60 from a syndicate of which he was a member, which amount represented "interest and dividend adjustments," and was the final…
2Cases cited1 opinion
- Heinz v. CommissionerUnited States Board of Tax Appeals · 1933