Spring City Foundry Co. v. Commissioner

*827OPINION.

Matthews :

1. The first issue before us is whether the petitioner is entitled to any deduction for the year 1920 on account of the debt owed by the Cotta Transmission Company on its notes and open account in the total amount of $39,983.27. The respondent has allowed $28,715.76, the amount of the debt less the amount received by the petitioner as dividends from the debtor’s trustee in bankruptcy, as a deduction in 1923.

The debt was charged off in its entirety on December 28, 1920, by the petitioner in good* faith and in the belief that little, if anything, would be paid by the receiver…