Legal Opinion

O. S. Stapley Co. v. Commissioner

United States Board of Tax Appeals

Decided September 26, 1928No. Docket No. 7685PublishedCited by 9 opinions

Action of the petitioner held to have been sufficient to effect substantial compliance with the statute with respect to charging off certain worthless accounts.

1Opinion of the Court

*559OPINION.

Littleton :

With respect to the debts represented by open accounts in the amount of $7,904.90, it was stipulated at the hearing that these accounts were ascertained to be worthless during the taxable year. This leaves for consideration with respect to this item only the question as to whether they were charged off within the meaning of the statute so as to entitle the petitioner to the deduction on account thereof. While we have held that the statute is clear and unambiguous as requiring that the accounts must be charged off, we have not required, nor do we think the statute…

2Cited by9 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. Brown v. United StatesCourt of Appeals for the Third Circuit · 1938
  3. Cammack v. United StatesCourt of Appeals for the Eighth Circuit · 1940
  4. American Cigarette & Cigar Co. v. BowersDistrict Court, S.D. New York · 1937
  5. Brown v. United StatesDistrict Court, E.D. Pennsylvania · 1937

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