Legal Opinion

Sailer v. Commissioner

United States Tax Court

Decided May 20, 1948No. Docket No. 13487Unpublished

Bad debts: Worthless notes. - Collateral Serial 6% coupon notes of the Level Club, Inc., became worthless prior to the year 1942 where the organization was adjudicated a bankrupt in 1930, although the New York Court of Appeals did not deny leave to appeal from an adverse judgment until 1942.

1Opinion of the Court

Andrew Jackson Sailer and Esther Cherry Sailer v. Commissioner.

Sailer v. Commissioner

Docket No. 13487.

United States Tax Court

1948 Tax Ct. Memo LEXIS 185; 7 T.C.M. (CCH) 300; T.C.M. (RIA) 48085;

May 20, 1948

Bad debts: Worthless notes. - Collateral Serial 6% coupon notes of the Level Club, Inc., became worthless prior to the year 1942 where the organization was adjudicated a bankrupt in 1930, although the New York Court of Appeals did not deny leave to appeal from an adverse judgment until 1942.

Palmer Watson, Esq., 1010 Real Estate Trust Bldg., Philadelphia, Pa., for the petitioners. Karl W.…

2Cases cited3 opinions

  1. Boehm v. CommissionerSupreme Court of the United States · 1945
  2. Hawke v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Eaton v. ReichNew York Court of Appeals · 1932

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