First National Bank, Parkers Landing v. Commissioner

*1388OPINION.

Sternhagen:

The facts before us indicate nothing as to actual worthlessness of the bonds or that a loss was in fact realized. The single reason for “ charging them off ” was an order of a national bank examiner. This does not prove either a loss sustained, under section 234 (a) (4) or a debt ascertained to be worthless under section 234 (a) (5), Revenue Act of 1921, Murchison National Bank, 1 B. T. A. 617; Farmers & Traders Bank, 4 B. T. A. 753; Continental Trust Co., 7 B. T. A. 539, 554. Nor are the facts sufficient to show the extent to which the debts, if they were to be treated as…