City Bank Farmers Trust Co. v. United States

The plaintiffs, as executors of the estate of William T. ■Carrington, deceased, have duly filed a claim for refund of taxes paid by the decedent for the year 1929 on the ground that in computing the taxes of the decedent for that year the Commissioner failed to allow $89,000 as a bad debt deduction by reason of which the decedent’s taxes were overpaid in the sum of $13,958.14, for which sum judgment is asked.

*549Tbe commissioner of this court found that in the years 1927 and 1928 the decedent made loans aggregating $89,000 to a corporation known as the American Society for Opera in English, Inc.,…