Legal Opinion

S. Rossin & Sons, Inc. v. Commissioner

United States Board of Tax Appeals

Decided December 26, 1939No. Docket Nos. 92942, 92943Published

The excess of a reserve for bad debts over the amount actually found to be unrecoverable held income for the year in which the reserve was closed out and distributed, even though petitioner had several years previously changed from the reserve to the specific bad debt method, with respondent's tacit approval, and even though all debts outstanding on the date of such change had been paid in full.

1Opinion of the Court

S. ROSSIN & SONS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ESTATE OF MARCO FLEISHMAN, BY ARTHUR J. COHEN AND MICHAEL SCHAAP, AS EXECUTORS, (TRANSFEREE), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

S. Rossin & Sons, Inc. v. Commissioner

Docket Nos. 92942, 92943.

United States Board of Tax Appeals

40 B.T.A. 1274; 1939 BTA LEXIS 730;

December 26, 1939, Promulgated

The excess of a reserve for bad debts over the amount actually found to be unrecoverable held income for the year in which the reserve was closed out and distributed, even though petitioner had…

2Cases cited12 opinions

  1. Tide Water Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Athol Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Dallas Title & Guaranty Co. v. CommissionerUnited States Board of Tax Appeals · 1939
  4. G. M. Standifer Constr. Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Home Ice Cream & Ice Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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