Harding v. United States

WHITAKER, Judge.

This is a suit to recover income taxes for the years 1944 and 1945. Plaintiff is entitled to recover if he is entitled to -carry back to those years a loss sustained by him in 1946 due to the charging off in that year of a bad debt in the sum of $345,746.28. He is entitled to do so if it was a loss “attributable to the operation of a trade or business regularly carried on by the taxpayer.”

This indebtedness, which turned out to be a bad debt, was incurred in this way:

Plaintiff was a member of the brokerage firm of Chas. D. Barney & Company, and in its successor partnership,…