Sass v. Commissioner
United States Board of Tax Appeals
Pursuant to an agreement of guaranty, the petitioner, in the year 1919, paid partly in cash and partly in notes, certain notes, the payment of which he had guaranteed. Held, in the absence of evidence as to the worthlessness of the notes so paid by cash and notes, no deduction may be taken as a worthless debt or as a loss on account thereof.
1Opinion of the Court
*558OPINION.
Love:
The petitioner claims that the transaction outlined in the findings of fact constitute a loss sustained under the provisions of section 214 (a) of the Revenue Act of 1918, and that the loss was sustained in the year 1919, since in that year he gave to the Bank his note for $19,253.54 and $4,899.58 in cash to cover unpaid notes held by the Bank, the payment of which the petitioner had guaranteed.
The respondent denies the right of the petitioner to deduct the amount represented, by the note given in 1919 by the petitioner to the Bank and further denies the propriety of his allowing…
2Cited by2 opinions
- Sass v. CommissionerUnited States Board of Tax Appeals · 1927
- Sass v. CommissionerUnited States Board of Tax Appeals · 1928