First Nat'l Bank v. Commissioner
United States Board of Tax Appeals
The decline in the value of Imperial Russian Government bonds acquired by petitioner as an investment which were not sold or otherwise disposed of during the taxable year may not be deducted as a bad debt uncollectible in part under the provisions of section 234(a)(5) of the Revenue Act of 1921. Since the bonds have not been shown to have been worthless at the end of the taxable year 1921, petitioner is not entitled to a deduction of the cost thereof as a loss sustained.
1Opinion of the Court
*34OPINION.
Littleton:
The claim advanced by the petitioner is that it is entitled to a deduction under section 234 (a) (5), Revenue Act of 1921, on account of certain Russian bonds purchased as an investment and which it claims were “ debts ascertained to be worthless ” in 1921 within the meaning of the statute. The Revenue Act of 1921, as well as the 1918 Act and the acts subsequent to 1921, provide for deductions on account of “ losses sustained ” and also for “ debts ascertained to be worthless.” In Appeal of Emil Sterna and Jules Stern, 5 B. T. A. 89, the Board said:
The Kevenue Act of 1918…
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- South Hills Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930