E. Richard Meinig Co. v. Commissioner
United States Tax Court
Income Tax -- Deduction -- Partially Worthless Debt. -- A taxpayer need not deduct for partial worthlessness in each year when some partial worthlessness develops, but can wait until further worthlessness occurs and deduct the total partial worthlessness at the later date.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency in income tax of $41,235.30 for 1941 and deficiencies in excess profits tax of $115,418.49 for 1941 and $37,346.60 for 1942. The petitioner claimed a deduction for 1939 of $615,143.40 representing the partial worthlessness of a debt in the amount of $640,774.38 due it from the Meinig Hosiery Co., hereafter called Hosiery. The Commissioner, in computing the net operating loss carry-over from prior years to 1941, disallowed $385,195.02 of the deduction claimed for 1939, “for the reason that it is held that the debt became worthless…
2Cases cited2 opinions
- Atlantic C. L. R. Co. v. CommissionerUnited States Tax Court · 1944
- Buck v. WilsonSupreme Court of Pennsylvania · 1886
3Cited by13 opinions
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
- Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
- Findley v. CommissionerUnited States Tax Court · 1955
- International Proprietaries, Inc. v. CommissionerUnited States Tax Court · 1952
- Capital Nat'l Bank v. CommissionerUnited States Tax Court · 1951
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