Rhinelander v. Commissioner

During 1928 and for many years prior thereto the petitioner's only business was that of acting as trustee, executor, and administrator. In 1917 and years prior thereto he loaned large sums of his own funds to the Atlantic Mortgage Corporation. He definitely ascertained in 1927 that his claim against the corporation for $163,585.61 was worthless. The amount of the deductible loss was in excess of his income for that year to the extent of $20,826.23. He claims the last named amount as a deduction from his gross income of 1928, under section 117(b) of the Revenue Act of 1928. Held, that the loss…