Legal Opinion

Pacific Novelty Co. v. Commissioner

United States Board of Tax Appeals

Decided January 8, 1927No. Docket No. 8162PublishedCited by 6 opinions

The amount by which a debt was reduced under the terms of a composition agreement was a deductible loss in the year in which the agreement was made.

1Opinion of the Court

*1018OPINION.

Milliken:

The question here presented is whether the deduction of $9,758.99, claimed by petitioner as a bad debt deduction for 1920, was an allowable deduction under section 234 of the Revenue Act of 1918. The respondent contends that the amount deducted was only a portion of a debt and as such is not deductible as a bad debt ascertained to be worthless and charged off within the year, under section 234 (a) (5). If the premise of such contention is correct, the conclusion is sound, for the reason that a part of a debt may not be claimed as a bad debt deduction, under the Revenue Act of…

2Cited by6 opinions

  1. Henry v. United StatesUnited States Court of Claims · 1960
  2. Sweinhart v. CommissionerUnited States Board of Tax Appeals · 1934
  3. H. Thorman v. CommissionerUnited States Tax Court · 1949
  4. Henry v. United StatesUnited States Court of Claims · 1960
  5. Kirkpatrick v. CommissionerUnited States Tax Court · 1944

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