Jarvis v. Commissioner
United States Tax Court
Held, loans made by petitioner to a corporation of which he was a stockholder that became worthless in 1953, were deductible only as nonbusiness bad debts under section 23(k)(4) and not deductible as business bad debts under section 23(k)(1).
1Opinion of the Court
MulRoney, Judge:
The respondent determined a deficiency in income tax and an addition to tax under section 294(d) (2) of the Internal Revenue Code of 1939 1 for the taxable year 1953 in the respective amounts of $3,062.26 and $297.59. The question in the case is whether certain loans made by petitioner to a corporation of which he was a stockholder, are deductible only as nonbusiness bad debts within the purview of section 23 (k) (4) or whether said amounts are deductible as business bad debts under section 23 (k) (1).
EINDINGS OF FACT.
Some of the facts were stipulated and they are found…
2Cases cited4 opinions
- Burnet v. ClarkSupreme Court of the United States · 1932
- Towers v. CommissionerUnited States Tax Court · 1955
- Barish v. CommissionerUnited States Tax Court · 1959
- Vreeland v. CommissionerUnited States Tax Court · 1958
3Cited by7 opinions
- Mitchell v. CommissionerUnited States Tax Court · 1966
- Gordy v. CommissionerUnited States Tax Court · 1961
- Gordy v. CommissionerUnited States Tax Court · 1961
- Jarvis v. CommissionerUnited States Tax Court · 1959
- Mitchell v. CommissionerUnited States Tax Court · 1966
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