Jones v. Commissioner of Internal Revenue

(after stating the facts as above).

The question before us is whether or not the facts presented by the record áre sufficient to justify the action of the Board of Tax Appeals in affirming respondent’s determination that the taxpayer was not entitled to deduct the worthless and unrecoverable parts of the bad debts, referred to in the statement of facts, in arriving at his net income for 1921 and 1922.

The ruling of the Commissioner of Internal Revenue being prima facie correct, the burden of proof is upon the taxpayer to establish his right to the deduction claimed. United States v. Rindskopf,…