Silberblatt v. Commissioner

*76OPINION.

Marquette:

There is no dispute concerning the fact of the total amount of loss sustained by the petitioner in connection with the Supreme Cloth Sponging Co. The point here in controversy is whether that loss occurred in 1925 or in 1926, either in whole or in part.

The loss consisted of two items. One item, for money loaned, amounted to $8,000. It seems clear to us from the record that petitioner sustained that loss in 1925. He knew in that year that the money loaned could never be recovered. By written contract in August 1925 petitioner agreed to cancel the debt if certain persons would…