Houk v. Commissioner of Internal Revenue

LEE, Circuit Judge.

Nine separate petitions to review decisions of the Tax Court holding petitioners liable for income tax deficiencies for the year 1941 bring this case before us.1 *Their common gravamen is the application of § 23(k) (1) of the Internal Revenue Code, as amended, 26 U.S.C.A. § 23(k) (1). Particularly, the controlling question is whether the McFaddin Trust is entitled, in computing its net income for the fiscal year ending February 28, 1941, to a deduction of $75,912.34,2 instead of $16,630.48, allowed by the Tax Court, for a bad debt, recoverable only in part. The petitioners…