Harris v. Commissioner

CHASE, Circuit Judge.

The petitioner took a deduction in his income tax return for 1936 for a bad debt determined to be worthless and charged off in that year, and claimed deductible under the provisions of § 23(k) of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, page 828. The commissioner disallowed it and determined a deficiency. The tax court upheld this determination upon finding that “the petitioner must have known long prior to 1936 that his debt was worthless.” This petition to review the redetermination of the deficiency presents two principal questions, which are (1) whether the…