Hart Furniture Co. v. Commissioner
United States Tax Court
1. Petitioner maintained its own books and those of other corporations operated by the same family. In attempting to balance the intercompany accounts existing between it and one other corporation, it discovered that they were out of balance in the amount of $ 400. Petitioner has sought to claim the amount as a deduction.
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1. Petitioner maintained its own books and those of other corporations operated by the same family. In attempting to balance the intercompany accounts existing between it and one other corporation, it discovered that they were out of balance in the amount of $ 400. Petitioner has sought to claim the amount as a deduction. Held, under the facts, petitioner is not entitled to a deduction therefor under any subdivision of section 23, I. R. C. 2. Through error, petitioner failed to claim a 90 per cent credit to which it was entitled in paying in 1945 its excise tax under the Federal Unemployment…
1Opinion of the Court
OPINION.
Kern, Judge:(1) Petitioner recognizes that the first issue “involves entirely a question of fact * * Unfortunately for petitioner, it has not presented sufficient facts to warrant our overturning respondent’s determination. Petitioner urges, upon brief, that the deduction should be allowed as a bad debt. Petitioner’s theory is that its former bookkeeper could not explain the discrepancy, that she was then “charged” by it with the liability, and that she could not pay the claim.
The facts are that neither the bookkeeper nor petitioner made any investigation whatsoever to discover the…
Also in this document: Dissent.
2Cases cited12 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Steward MacHine Co. v. DavisSupreme Court of the United States · 1937
- Massachusetts v. United StatesSupreme Court of the United States · 1948
- Illinois Ex Rel. Gordon v. CampbellSupreme Court of the United States · 1946
7 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Kenyon Instrument Co. v. CommissionerUnited States Tax Court · 1951
- Schering Corp. v. CommissionerUnited States Tax Court · 1978
- Leonhart v. CommissionerUnited States Tax Court · 1968
- Markson Bros. v. CommissionerUnited States Tax Court · 1950
- Drew v. CommissionerUnited States Tax Court · 1972
4 more not listed; retrieve them via the Exa API.