Rogers Peet Co. v. Commissioner
United States Board of Tax Appeals
1. Since the record does not disclose that there were dificiencies for the taxable years 1923 and 1924, the proceeding will be dismissed as to those years. 2. In its returns for 1921 and 1922 the petitioner took deductions for specific bad debts actually charged off. It also took as deductions for bad debts certain additional amounts representing additions made to a reserve.
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1. Since the record does not disclose that there were dificiencies for the taxable years 1923 and 1924, the proceeding will be dismissed as to those years. 2. In its returns for 1921 and 1922 the petitioner took deductions for specific bad debts actually charged off. It also took as deductions for bad debts certain additional amounts representing additions made to a reserve. For the year 1921 the amount of the addition to the reserve represented the amount of the deficit or the excess of liabilities over assets disclosed by the balance sheet of a deferred creditor of the petitioner. The…
1Opinion of the Court
*580OPINION.
TRAMmell:
For the fiscal years ended February 28, 1923, and February 28, 1924, the respondent has determined over assessments. It not appearing that there were deficiencies for the years, the appeal will be dismissed with respect thereto. Cornelius Cotton Mills, 4 B.T.A. 255.
The petitioner contends that for the fiscal years ended February 28, 1921, and February 28, 1922, it is entitled to deductions of $33,441.25 and $40,561.96 respectively, representing the portions of the indebtedness of Anderson & Brothers ascertained to be worthless and charged off within the respective taxable…
2Cases cited1 opinion
- Cornelius Cotton Mills v. CommissionerUnited States Board of Tax Appeals · 1926
3Cited by2 opinions
- Randall v. CommissionerUnited States Tax Court · 1980
- Rogers Peet Co. v. CommissionerUnited States Board of Tax Appeals · 1930