Legal Opinion

Murchison Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided February 26, 1925No. Docket No. 608Published

Under section 234(a)(5) of the Revenue Act of 1918, a part of a debt may not be written off as worthless and the other part maintained on the books of taxpayer as having a value. (Appeal of Steele Cotton Mill Company,1 B.T.A. 299.) A taxpayer holding collateral security for the payment of a debt may not write off as worthless, under section 234(a)(5) of the Revenue Act of 1918, the difference between the amount of the debt and the estimated value of the security.

1Opinion of the Court

Appeal of THE MURCHISON NATIONAL BANK.

Murchison Nat'l Bank v. Commissioner

Docket No. 608.

United States Board of Tax Appeals

1 B.T.A. 617; 1925 BTA LEXIS 2856;

February 26, 1925, decided Submitted January 13, 1925.

Under section 234(a)(5) of the Revenue Act of 1918, a part of a debt may not be written off as worthless and the other part maintained on the books of taxpayer as having a value. (Appeal of Steele Cotton Mill Company,1 B.T.A. 299.)

A taxpayer holding collateral security for the payment of a debt may not write off as worthless, under section 234(a)(5) of the Revenue Act of 1918, the…

2Cases cited2 opinions

  1. Steele Cotton Mill Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  2. Murchison Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1925

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