Legal Opinion

Colvert v. Commissioner

United States Board of Tax Appeals

Decided March 26, 1927No. Docket No. 9170Published

1. The debt herein was properly ascertained to be worthless and charged off in the taxable year, and constituted a deduction from gross income. 2. A taxpayer on the cash receipts and disbursements basis may not deduct from gross income the amount of a note given for an antecedent obligation, where it is not shown that the note was accepted as payment.

1Opinion of the Court

WARNER L. COLVERT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Colvert v. Commissioner

Docket No. 9170.

United States Board of Tax Appeals

6 B.T.A. 623; 1927 BTA LEXIS 3462;

March 26, 1927, Promulgated

1. The debt herein was properly ascertained to be worthless and charged off in the taxable year, and constituted a deduction from gross income.

2. A taxpayer on the cash receipts and disbursements basis may not deduct from gross income the amount of a note given for an antecedent obligation, where it is not shown that the note was accepted as payment.

Charles H. Garnett, Esq., for the…

2Cases cited1 opinion

  1. Colvert v. CommissionerUnited States Board of Tax Appeals · 1927

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