Legal Opinion

West Lafayette Bank v. Commissioner

United States Board of Tax Appeals

Decided July 16, 1928No. Docket No. 20201Published

The fact that a bank writes down or charges off against bonds owned by it reductions in the market value thereof upon the orders of the State Banking Department is not sufficient to establish that such amounts so charged off are debts ascertained to be worthless, in whole or in part, within the taxable year.

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The fact that a bank writes down or charges off against bonds owned by it reductions in the market value thereof upon the orders of the State Banking Department is not sufficient to establish that such amounts so charged off are debts ascertained to be worthless, in whole or in part, within the taxable year. Bonds generally represent an investment in property from which gain is realized or loss sustained upon the sale or other disposition and are not such debts as are contemplated by the provisions of the Revenue laws permitting deductions for bad debts.

1Opinion of the Court

WEST LAFAYETTE BANK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

West Lafayette Bank v. Commissioner

Docket No. 20201.

United States Board of Tax Appeals

12 B.T.A. 1356; 1928 BTA LEXIS 3354;

July 16, 1928, Promulgated

The fact that a bank writes down or charges off against bonds owned by it reductions in the market value thereof upon the orders of the State Banking Department is not sufficient to establish that such amounts so charged off are debts ascertained to be worthless, in whole or in part, within the taxable year. Bonds generally represent an investment in property from…

2Cases cited1 opinion

  1. West Lafayette Bank v. CommissionerUnited States Board of Tax Appeals · 1928

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