Dallmeyer v. Commissioner
United States Tax Court
Prior to December 17, 1941, petitioner made unsecured loans to Cole Motor Service, Inc., totaling $ 17,561.33. Prior also to that date the Exchange National Bank, of which petitioner was president, loaned Cole Motor Service a total of $ 27,511.38. On that date Cole Motor Service filed a petition for reorganization under chapter X of the Bankruptcy Laws of the United States.
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Prior to December 17, 1941, petitioner made unsecured loans to Cole Motor Service, Inc., totaling $ 17,561.33. Prior also to that date the Exchange National Bank, of which petitioner was president, loaned Cole Motor Service a total of $ 27,511.38. On that date Cole Motor Service filed a petition for reorganization under chapter X of the Bankruptcy Laws of the United States. On May 11, 1942, petitioner acquired the unsecured notes of Cole Motor Service held by the Exchange National Bank in exchange for collateral he had previously put up to guarantee their payment. On October 28, 1943, Cole…
1Opinion of the Court
OPINION.
Hill, Judge:
Petitioner first contends that he is entitled under section 23 (k) (1) of the code to a business bad debt deduction of $9,233.53 in 1944, that being the alleged adjusted basis in his hands of the unsecured promissory notes of Cole Motor totaling $12,311.38 which he acquired from the Exchange National Bank in 1942. His second contention is that in 1944 he suffered a nonbusiness bad debt loss of $17,561.33 on' loans he personally made to Cole Motor and therefore he is entitled under section 23 (k) (4) to deduct $1,000 in 1944 as a short term capital loss. Furthermore, he…
2Cases cited6 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
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